Last updated: 8 September 2022

Quals Business Consultants Pte Ltd

In regulatory compliance with the Singapore Personal Data Protection Act (PDPA) 2012, Quals Business Consultants Pte Ltd (“Quals”) respects the privacy and confidentiality in the personal data of our clients, associates, employees and others. Our company and its employees are committed and adhered with the implementation of data protection policies in best practices including strict processes to safeguard our collection, use and disclosure of the stated.

This Data Privacy Notice can assist in understanding of how we at Quals collect, use, disclose, process, protect and retain personal data in possession.

1   How We Collect Personal Data

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when in combination with possibly other information.  Under Singapore’s PDPA, business contact information (e.g. full name, business address, business telephone number, corporate emails) are not considered as personal data when such are being used for business-to-business (B-B).

Quals collects personal data in the following general circumstances:

• Our candidates in job applications
• Our employees
• Any communication in the capacity as an individual via unsolicited emails, written correspondences, a personal enquiry on our website contact form

In our professional services capacity, we also collect personal data in the working operations of our Human Resources and Payroll divisions in the following general circumstances:

• Companies’ employees
• Human Resources matters and Payrolls via corporate emails by authorized personnel reciprocally which had been assigned

2   Types of Personal Data We Collect

The types of personal data we may collect where necessary:

• Contactable information (Name, personal mobile phone number, personal email Address)
• Full Personal details (Name, Gender, Date of Birth, Nationality etc.)

In our professional services capacity, we also collect personal data in the working operations of our Human Resources and Payroll divisions:

• Full Personal details (Name, Gender, Date of Birth, Nationality etc.)
• Other required details and/ or documentation as in part or whole as furnished (Bank accounts, Religion, Medical Declaration, Next of Kin details etc.)

3   How We Use Personal Data

We use the personal data provided to us for one or more of the following purposes:

• Provide employment opportunities
• Process human resource matters
• Process salary and remuneration matters
• Communicate with website visitors
• Carry out our obligations arising from any contracts entered into between our clients and us
• Comply with or fulfil legal obligations and regulatory requirements

4   Who We Disclose Personal Data To

Personal Data disclosed to us are fully kept in-house in Quals with strict controls and access only by authorized employees respectively assigned to fulfil our professional services and for the circumstances as stated above.

The exception where required by law, we may disclose personal data to the relevant authorities or to law enforcement agencies.

5   How We Manage the Collection, Use and Disclosure of Personal Data

5.1       Obtaining Consent

Before we collect, use or disclose any personal data, we will notify our purpose intended to obtaining a written confirmation in expressed consent. We will not collect personal data information beyond the necessary for facilitating the stated purpose.  We will seek further consent from the intended recipient if the original purpose intended for the collection, use or disclosure of your personal data has been changed.

Under certain circumstances, we may assume deemed consent when there is/are voluntarily provision of personal data for the stated purpose and circumstances, e.g. when applying for a job with us by sending in your resume/CV containing personal information or the personal data information as given whether in part or whole to perform our working operations professional obligations of Human Resources and Payroll matters.

We may rely on the exceptions to the need for consent under the PDPA for the collection, use or disclosure of personal data under the following circumstances:

• • The personal data is publicly available
  • The personal data is being disclosed by a public agency or disclosed to a public agency
  • The personal data is necessary for any investigation or proceedings

• • The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
  • The personal data is necessary for the purpose of managing or terminating an employment relationship
  • The personal data is necessary for a business asset transaction
  • The personal data is given by our clients to perform services of Human Resources and Payroll matters

5.2       Withdrawal of Consent

In the event of an intention in withdrawal of consent, a request via written correspondence can be sent to us. Adhering to reasonable advance notice, we will advise of the likely consequences of the withdrawal of consent, e.g. without personal contact information, we may not be able to inform the intended recipient of future services provided by us or unable to transfer payroll to employees.

5.3       Use of Cookies on Corporate Website

We use “cookies” to collect information about online activity on our corporate website. A cookie is a small text file created by the website that is being stored in computer to provide a way for the website in recognizing user to keep track of preferences.  The cookie makes it convenient in not having to key in repeated information upon revisiting our website or in filling out any electronic forms.

Most cookies we use are “session cookies”, which will be automatically deleted from the hard disk of the computer at the end of the session. The choice of not to accept cookies is available by turning off this feature in the web browser. However, some of the features and functions in our web applications may not then be available for usage.

5.4       Third-Party Consent

We only get direct consent from an individual and do not get consent on behalf of another individual.

6   How We Ensure the Accuracy Personal Data

We take reasonable steps to ensure the personal data we collect is accurate, complete and up-to-date.  We may conduct periodically a data verification exercise in updating any changes to the personal data we hold.

7   How We Protect Personal Data

We have implemented appropriate information security and technical measures to protect the personal data we hold in preventing unauthorized access, unauthorized loss; unauthorized alteration/modification, misuse, disclosure and/or similar risks. We adhered to using approved security disposal services of our IT Assets and documentation.

We have also put in place reasonable and appropriate organizational measures to maintain the confidentiality and integrity of personal data, and will only share data with assigned authorized persons on a ‘need to know’ basis.

When we engage third-party vendor in our work scope which may comprise of data (E.g. Auditors), we will ensure that they provide sufficient guarantees to us to have implemented the necessary organizational and technical security measures, and have taken reasonable steps to comply accordingly.

8   How We Retain Your Personal Data

Quals have document retention policy to keeps track of the retention schedules of the personal data provided to us, in paper or electronic forms.  We will not retain any personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing personal data in a proper and secure manner accordingly to the retention dateline set.

9   How You Can Access and Make Correction to Your Personal Data

Anyone may write in to us to find out how we have been using or disclosing their personal data over the past one year.  Before we accede to the intended recipient’s request, we may need to make identity verification through legal identification documents.  We will respond to your request as soon as possible, or within 30 days from the date we receive the stated request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of timeline that we may require. We may also charge a reasonable fee for the cost involved in processing the access request.

If the information we hold about the recipient is inaccurate, incomplete or not up-to-date, please ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive the request.

10   Transfer of Personal Data

Where a need arises to transfer personal data to another country outside of Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

11   Contacting Us

If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: privacy@qualsbiz.com

Any query or complaint should include, at least, the following details:

• Your full name and contact information
• Brief description of your query or complaint

We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.

12   Changes to this Data Privacy Notice

We may update this Data Privacy Notice from time to time and please visit the latest notice on our corporate website at www.qualsbiz.com for any updates.