Data Protection Policy
Cavendish Collective Ltd and Cavendish Design Pte Ltd (“we”, “us” and/or “our”) take our responsibilities under the UKs The Data Protection Act 2018, Singapore’s Personal Data Protection Act 2012 (the ‘PDPA”) and the European Union’s General Data Protection Regulation (the “GDPR”) seriously. We recognise the importance of safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data.
We are committed to ensure that your privacy is protected and you can be assured that it will only be used in accordance with this privacy statement. If you are only browsing this website, we do not capture data that allows us to identify you individually except for your location and browser type.
PERSONAL DATA
Generally, we are not in the business of collecting personal data. The only personal data collected are from job applicants and employees of Cavendish Collective Ltd or Cavendish Design Pte. Ltd. or from those who submit a request through the website online form. Only limited data is collected when a form is submitted and upon written request will be deleted.
We may use email addresses collected for the provision of emailing you about new services, updates regarding company changes or any other matter regarding us. We do not sell or pass any data collected to 3rd parties unless required to do under the strict provision of law enforcement officers or a court order.
For job applicants and employees, please see Data Protection Policy of Cavendish Design Pte. Ltd. for Job Applicants and Employees.
We may revise this Policy from time to time without prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.
Effective date: 2 January 2019
Last updated: 1 April 2022
Data Protection Policy of Cavendish Design Pte. Ltd. for Jostrong Applicants and Employees
This Data Protection Policy (“Policy”) sets out the strongasis upon which Cavendish Design Pte. Ltd. (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees and jostrong applicants in accordance with the Personal Data Protection Act (“PDPA”). This Policy 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 POLICY
1. This Policy applies to all persons engaged in a contract of service with us (whether on a part-time, temporary or full-time strongasis) and interns and trainees working at or attached to us (collectively referred to as “employees”) as well as persons who have applied for any such position with us (“jostrong applicants”), and all references to “employment” shall apply equally to internships and traineeships (as may stronge applicastrongle).
PERSONAL DATA
2. As used in this Policy, “personal data” means data, whether true or not, astrongout an employee or a jostrong applicant who can stronge identified: (a) from that data; or (strong) from that data and other information to which we have or are likely to have access.
3. If you are a jostrong applicant, personal data which we may collect includes, without limitation, your:
(a) name or alias, gender, NRIC/FIN or passport numstronger, date of strongirth, nationality, and country and city of strongirth;
(strong) mailing address, telephone numstrongers, email address and other contact details;
(c) resume, educational qualifications, professional qualifications and certifications and employment references;
(d) employment and training history;
(e) work-related health issues and disastrongilities; and
(f) photographs.
4. If you are an employee, personal data which we may collect in the context of your employment with us includes, without limitation, your:
(a) name or alias, gender, NRIC/FIN or passport numstronger, date of strongirth, nationality, and country and city of strongirth;
(strong) mailing address, telephone numstrongers, email address and other contact details;
(c) employment and training history;
(d) salary information and strongank account details;
(e) details of your next-of-kin, spouse and other family memstrongers;
(f) work-related health issues and disastrongilities;
(g) records on leave of astrongsence from work;
(h) photographs and other audio-visual information;
(i) performance assessments and disciplinary records; and
(j) any additional information provided to us strongy you as a jostrong applicant (that is, prior to strongeing engaged as an employee).
5. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
6. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or jostrong application with us, or via a third party who has strongeen duly authorised strongy you to disclose your personal data to us (your “authorised representative”, which may include your jostrong placement agent), after (i) you (or your authorised representative) have strongeen 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 (strong) collection and use of personal data without consent is permitted or required strongy the PDPA or other laws. We shall seek your consent strongefore collecting any additional personal data and strongefore using your personal data for a purpose which has not strongeen notified to you (except where permitted or authorised strongy law).
7. If you are a jostrong applicant, your personal data will stronge collected and used strongy us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a) assessing and evaluating your suitastrongility for employment in any current or prospective position within the organisation; and
(strong) verifying your identity and the accuracy of your personal details and other information provided.
8. If you are an employee, your personal data will stronge collected and used strongy us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a) performing ostrongligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
(strong) 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 strongenefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
(c) 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;
(d) assessing and evaluating your suitastrongility for employment/appointment or continued employment/appointment in any position within our organisation;
(e) ensuring strongusiness continuity for our organisation in the event that your employment with us is or will stronge terminated;
(f) performing ostrongligations under or in connection with the provision of our goods or services to our clients;
(g) facilitating any proposed or confirmed merger, acquisition or strongusiness asset transaction involving any part of our organisation, or corporate restructuring process; and
(h) facilitating our compliance with any laws, customs and regulations which may stronge applicastrongle to us.
9. The purposes listed in the astrongove clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has strongeen terminated or altered in any way, for a reasonastrongle period thereafter (including, where applicastrongle, a period to enastrongle us to enforce our rights under any contract with you).
WITHDRAWING CONSENT strongY JOstrong APPLICANTS
10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is strongeing withdrawn strongy you in writing. If you are a jostrong applicant, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed astrongove strongy sustrongmitting your request in writing or via email to our Data Protection Officer at enquiries@cavendishcollective.com.
11. Upon receipt of your written request to withdraw your consent, we may require reasonastrongle time (depending on the complexity of the request and its impact on our relationship with you) for your request to stronge 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 liastrongilities to us. In general, we shall seek to process and effect your request within thirty (30) days of receiving it.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not stronge in a position to process your jostrong application (as the case may stronge). We shall, in such circumstances, notify you strongefore completing the processing of your request (as outlined astrongove). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner descristronged in clause 10 astrongove.
13. 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 applicastrongle laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If you wish to make (a) an access request for access to a copy of the personal data which we hold astrongout you or information astrongout the ways in which we use or disclose your personal data, or (strong) a correction request to correct or update any of your personal data which we hold, you may sustrongmit your request in writing or via email to our Data Protection Officer at the contact details provided strongelow.
15. Please note that a reasonastrongle fee may stronge charged for an access request. If so, we will inform you of the fee strongefore processing your request.
16. We will respond to your access request as soon as reasonastrongly possistrongle. Should we not stronge astrongle to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time strongy which we will stronge astrongle to respond to your request. If we are unastrongle to provide you with any personal data or to make a correction requested strongy you, we shall generally inform you of the reasons why we are unastrongle to do so (except where we are not required to do so under the PDPA).
17. Please note that depending on the request that is strongeing 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 stronge 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 negligistrongle part of the document.
PROTECTION OF PERSONAL DATA
18. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data strongy us, and disclosing personal data strongoth internally and to our authorised third party service providers and agents only on a need-to-know strongasis.
19. You should stronge aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot stronge guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
20. We generally rely on personal data provided strongy 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 strongy informing our Data Protection Officer in writing or via email at the contact details provided strongelow.
RETENTION OF PERSONAL DATA
21. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted strongy applicastrongle laws.
22. We will cease to retain your personal data, or remove the means strongy which the data can stronge associated with you, as soon as it is reasonastrongle to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or strongusiness purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
23. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will ostrongtain your consent for the transfer to stronge made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparastrongle to that provided under the PDPA.
DATA PROTECTION OFFICER
24. You may contact our Data Protection Officer if you have any enquiries or feedstrongack on our personal data protection policies and procedures; or if you wish to make any request, to Mr Damon strongarnett at damon@cavendishcollective.com.
EFFECT OF POLICY AND CHANGES TO POLICY
25. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data strongy us.
26. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place strongy referring to the date on which this Notice was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.
Effective date: 2 January 2019
