DATA PROTECTION NOTICE FOR CUSTOMERS, EMPLOYEES AND JOB APPLICANTS
This Data Protection Notice (“Notice”) sets out the basis which TERRA SYSTEMS PTE. LTD. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers, employees and job applicants in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
APPLICATION OF THIS NOTICE
- FOR JOB APPLICANTS: This Notice applies to all persons who have applied for any positions with us (“job applicants”).
- FOR EMPLOYEES: This Notice applies to all persons engaged in a contract of service with us (whether on a part-time, temporary or full-time basis) and interns and trainees working at or attached to us (collectively referred to as “employees”), and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).
- FOR EMPLOYEES AND JOB APPLICANTS: Personal data which we may collect in the context of your employment or application with us includes, without limitation, your:
- Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
- Mailing address, telephone numbers, email address and other contact details;
- Employment and training history;
- Salary information and bank account details;
- Details of your next-of-kin, spouse and other family members;
- Work-related health issues and disabilities;
- Records on leave of absence from work;
- Photographs and other audio-visual information;
- Performance assessments and disciplinary records; and
- Any additional information provided to us by you as a job applicant (that is, prior to being engaged as an employee).
- FOR CUSTOMERS: This Notice applies to all customers. “Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.
- DEFINITION: “personal data” means data, whether true or not, about a customer, employee, or job applicant who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- FOR EMPLOYEES AND JOB APPLICANTS: We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- FOR CUSTOMERS: We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- FOR EMPLOYEES AND JOB APPLICANTS: Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
- assessing and evaluating your suitability for employment in any current or prospective position within the organisation;
- verifying your identity and the accuracy of your personal details and other information provided;
- performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
- all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
- managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
- assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
- ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
- performing obligations under or in connection with the provision of our goods or services to our clients;
- facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
- facilitating our compliance with any laws, customs and regulations which may be applicable to us.
- FOR CUSTOMERS: We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
DEEMED CONSENT BY NOTIFICATION
- We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses 5 and 6. If TERRA SYSTEMS PTE. LTD. intends to rely on deemed consent by notification for such secondary purposes, TERRA SYSTEMS PTE. LTD. will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.
- In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
- FOR CUSTOMERS: Personal data may be disclosed to another organisation or third party in order to deliver the goods or services purchased.
- FOR EMPLOYEES AND JOB APPLICANTS: Personal data of employees or prospective employees may be passed on to third parties for the purposes of screening and security clearance.
- Before relying on such deemed consent by notification, TERRA SYSTEMS PTE. LTD. will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
- You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
- After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
- In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of TERRA SYSTEMS PTE. LTD. or another person. In relying on the legitimate interests exception of the PDPA, TERRA SYSTEMS PTE. LTD. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
- In line with the legitimate interests’ exception, we may collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and
- Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officers at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
- FOR CUSTOMERS: Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing to our Data Protection Officers at the contact details provided below.
- FOR JOB APPLICANTS: Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing to our Data Protection Officers at the contact details provided below.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officers at the contact details provided below.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- FOR EMPLOYEES: Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officers in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICERS
- You may contact our Data Protection Officers if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : EDMUND LIU
Email Address : EDMUND.LIU@TERRA.SYSTEMS
Name of DPO : GABRIEL SEE
Email Address : GABRIEL.SEE@TERRA.SYSTEMS
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.
- FOR CUSTOMERS: Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
- FOR EMPLOYEES AND JOB APPLICANTS: Your continued employment and participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.