This Recruitment Data Privacy Policy explains how Swire Shipping Pte Ltd and all its subsidiaries (hereinafter collectively referred to as “the Company”, “we” or “us”) manages the personal data about job applicants.
This Recruitment Data Privacy Policy explains what personal data we collect from individuals who apply for any employment, job, or internship with the Company, for which purposes we collect, how we use such personal data, how long we retain personal data, the rights of the individuals for their personal data and how to contact us for information.
It applies to applications submitted via Company’s career website, including via third-party systems, third parties, such as recruitment agencies, job boards and other means, such as by post and email.
1. Definitions
| Personal Data | Means any information (e.g. names, contact detail, passport number, biometric data, health data etc) relating to an identified or identifiable natural person (e.g. customer, employee etc). |
2. Personal Data We Collect
Your personal data is processed by Swire Shipping Pte Ltd and all its subsidiaries (hereinafter collectively referred to as “the Company”, “we” or “us”). Generally, the Company will only collect personal data in the recruitment process that is necessary to assess you for the position for which you have applied. The Company that you apply to will be the Data Controller of that personal data.
As part of your recruitment process, we may collect the following personal data about you (whether such information is provided by you or a third party):
| Personal Data Collected | Legal Grounds of Processing |
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Personal information such as: • Your name, address and contact details, your nationality, racial or ethnic origin (where the processing is required to comply with local law), date of birth, marital status, place of residence, religion (if applicable) • Social security number, passport number, visa, permission to work documentation or other national identification numbers. • CV, application form details. • Employment history, reference information, Professional qualifications, licenses, and training certificates. • Education history and transcripts. • Health data, while we do not generally collect your health data for recruitment purposes, where required or permitted by local law to assess your fitness to work, we will process your health data strictly for such purpose only. • Insofar as permitted by law, information received relating to criminal records or financial probity checks or other independent searches (and where we do so you will be asked to consent to such collection and use before we or agents undertake the search).
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a) The processing is necessary to perform an agreement we already have with you or to take steps to enter into an agreement with you (e.g. a contract of employment) b) For our legitimate business interests (where we have considered these are not overridden by your rights). c) To comply with applicable laws, regulations, legal processes, or governmental requests – these may include but are not limited to equal employment opportunities, minimum legal working age, local content requirements under applicable law. d) With your consent – where none of the above legal basis applies, we will process your Personal Data based on your explicit written consent. If so, we will provide you with full details of the information that we require and the reason we need it, so that you can carefully consider whether you wish to consent. You have the right to withdraw your consent at any time and this will not affect the validity of our processing of your Personal Data prior to your withdrawal of consent. |
If you fail to provide the personal data requested, in some circumstances this may mean the Company is unable to process your application.
3. How we collect information about you
Generally, we collect your personal data either a). directly from you when submit a job application or CV to us or b). from third parties with whom you have registered an interest in working for the Company (e.g. from recruitment agencies).
In considering your application we may also obtain information from third party sources such as our business partners, employment agencies, past employers, referees that you specify, educational institutions, credit reference agencies, other background check agencies, sanctions and politically exposed person screening lists or public registers, publicly available sources including [LinkedIn, Facebook and Google+] (“Social Network Sites”) when you choose to provide us with a link to your profile on any Social Network Site as part of your job application.
We may also obtain your contact details from publicly available sources, including content that you have made public on other Social Network Sites or similar sites for professional purposes to make initial contact with you for recruitment purposes. If we contact, you in this way you will be given the opportunity to opt-out of receiving any further information about career opportunities with the SSL Group and you can subsequently opt-out at any time by contacting the Company’s DPO by emailing DataProtection@swireshipping.com.
If you give us information about other individuals – for example, referees – or you are providing information about applicants to us in your capacity as a recruitment agency, you must first make sure that the individual knows that you might disclose information about them (either specifically to us or, at least, to potential employers) and you have obtained all relevant written consents from that individual to do so on their behalf. You are required to either confirm or to provide the Company with copies of all relevant written consents from that individual.
If you are a recruitment agency you should make sure that the Company’s Recruitment Data Privacy Policy is communicated to the applicant and all relevant written consents from the applicant had been obtained before sending the CV of the applicant to the Company.
4. What We Do With The Information We Gather
Your personal data will be processed for the purposes of
- Assessing your suitability for the advertised role or other potential vacancies within the Company (if you opted-in to consent the Company to retain your CVs for such a purpose);
- Preparing for the on-boarding, such as employment visa application, reference checking and/or employment contract preparation;
- Complying with our legal obligations, such as assisting with proceedings or investigations as required by public authorities, law enforcement agencies and regulators;
- Administering Company’s recruitment programme and compliance with related internal policies (such as our equal opportunity, modern slavery, and human trafficking policies) and for statistical purposes and
- Providing you with information about other job vacancies if you would like the Company to send you such notifications.
5. Sharing Your Information
We permit our authorised third-party service providers and the Company’s other offices to use your personal data on our behalf for the purposes as set out above. Where reasonably necessary or required to do so by law, we may disclose your personal data to third parties in response to a legitimate request for assistance by law enforcement or regulatory investigations, to protect your vital interests or safety and to seek legal advice from the Company’s external lawyers or in connection with litigation with a third party.
Sometimes your personal data may be transferred to, and stored at, in different jurisdictions, where the personal data Protection Laws and practices are likely to be different and may be less stringent than those within the jurisdiction in which you are resident. In such cases, we will ensure that there are adequate contractual and technical measures to ensure that your personal data is processed strictly on a need-to-know basis for the purposes mentioned above and that an appropriate level of protection is given to the personal data.
6. Safeguarding Personal Data
No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially appropriate physical, electronic and procedural safeguards to protect your personal data in accordance with the requirements of Personal Data Protection Laws.
We value the privacy of your personal data. All personal data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and we restrict access to your personal data to those persons who need to use it for the purpose(s) for which it was collected.
7. Your Rights
You have the right (subject to various exceptions and in accordance with applicable Personal Data Protection Laws in your country) to access certain personal data held about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with applicable Personal Data Protection Laws in your country.
You also have the right to raise a complaint about our processing with the applicable Data Protection Authority in our country or with our Data Protection Officer at DataProtection@swireshipping.com. Any request to exercise these rights will be assessed by us on a case-by-case basis.
8. Automated Processing
We do not carry out automated decision-making or profiling in relation to your personal data.
9. Retention Period
We keep records of your personal data for no longer than is necessary for the purpose for which we obtained them in accordance with our internal retention policies and procedures or as otherwise permitted by applicable law or to defend ourselves if we consider a complaint or dispute to be likely or until the position is filled.
If your application is unsuccessful, we may retain and use the information which you had provided for one (1) year from the date the job position that you had applied had been filled, this is to deal with any matter which may arise in connection with your application and for purposes of contacting you in connection with ongoing recruitment opportunities. If you do not wish to be considered for positions in the Company other than that you have applied for, please state in your cover letter the following: I do not wish to be considered for positions other than that I have applied.
If you are successful in your application, the information collected during your application and recruitment process will become part of your employment record and will be used and retained in accordance with our policies.
10. Changes to Policy
We may change the policy from time to time in the future. We encourage you to review them when you visit the website to stay informed of how we are using personal data.