Your privacy matters to us.

Talent First Pte. Ltd. is a recruitment and employment agency based in Singapore (Employment Agency Licence No. 26C3535, issued by the Ministry of Manpower). We are committed to protecting the personal data entrusted to us and to handling it in accordance with the PDPA and PDPC guidelines.

This Privacy Notice explains how we collect, use, disclose, protect and retain your personal data, the purposes for which we do so, and the rights and choices available to you. It applies to personal data we process through our website www.talentfirst.com.sg, our offices, and in the course of providing our recruitment and related services.

“Personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information to which we have or are likely to have access. By interacting with us, submitting your personal data to us, or using our website and services, you acknowledge that you have read and understood this Notice.

This Notice applies to the personal data of the following individuals (collectively, “you”):

• Candidates and job applicants: individuals who apply for, are sourced for, or are placed in roles through us;
• Clients and client contacts: representatives of organisations that engage us to source candidates;
• Referees: individuals nominated to provide references in support of a candidate;
• Website visitors: individuals who browse or submit information through our website; and
• Suppliers, vendors and other business contacts: we deal with in the course of our operations.

Depending on your relationship with us, we may collect the following categories of personal data. We collect only what is reasonable and necessary for the purposes set out in this Notice.

3.1 Candidates and job applicants

• Identity and contact details: name, email address, telephone number, mailing address, date of birth, gender, nationality and citizenship/residency status;
• Professional information: curriculum vitae/resume, cover letter, employment history, education and qualifications, professional certifications, skills, references, current and expected remuneration, notice period and availability;
• Right-to-work information: work pass/permit details, visa or immigration status, and eligibility to work in the relevant jurisdiction;
• Assessment information: interview notes, assessment and test results, and feedback from clients and referees;
• Background screening information: where relevant to a role and where we have a proper basis to do so, results of background, employment, education, credit or criminal-record checks;
• Sensitive information: where genuinely required for a specific role or to comply with the law (for example, certain health information for roles with medical requirements), and collected with appropriate consent or under a permitted basis under the PDPA;
• Technical and usage data: information collected automatically when you use our website (see Section 13).

NRIC / FIN and national identification numbers. Consistent with PDPC guidance, we do not collect your NRIC or FIN number (or a copy of your NRIC/FIN) at the application stage. We collect these only where there is a lawful basis to do so (see Section 7).

3.2 Clients, referees, suppliers and website visitors

• Clients and client contacts: name, job title, business contact details, and information relevant to a recruitment assignment;
• Referees: name, relationship to the candidate, business contact details, and the contents of the reference provided;
• Suppliers and business contacts: name, business contact details and information relevant to our dealings; and
• Website visitors: information you submit through enquiry or sign-up forms, and technical data described in Section 13.

We collect personal data through the following channels:

• Directly from you: when you submit a CV or enquiry, register with us, attend an interview, or otherwise communicate with us;
• From job portals and professional networking platforms: where you have made your profile or details available for recruitment purposes. Where you make your personal data available on such platforms to be contacted about job opportunities, you may be deemed under the PDPA to have consented to our collection and use of that data for those purposes;
• From referrals: where a contact or referee provides your details. If you are referred to us, we will inform you and rely on an appropriate basis under the PDPA;
• From third parties: such as referees, former employers, and background-screening providers engaged with your knowledge; and
• Automatically: through cookies and similar technologies when you use our website (see Section 13).

We collect, use and disclose your personal data for purposes that a reasonable person would consider appropriate in the circumstances, including to:

• assess your suitability for current and future roles, and match you with suitable opportunities;
• submit your profile to prospective employers and manage the application, interview and placement process;
• conduct, where appropriate, reference checks and background screening;
• provide our recruitment, executive search and related services to clients;
• communicate with you about opportunities, applications and our services;
• maintain and improve our candidate and client databases;
• comply with applicable laws, regulations and lawful requests from public authorities;
• prevent, detect and investigate fraud, misconduct or unlawful activity, and to protect our rights and the safety of individuals; and
• send you marketing or career-related updates, where you have consented to receive them (you may opt out at any time; see Section 12).

Where we intend to use your personal data for a purpose not described in this Notice, we will notify you and, where required, obtain your consent before doing so.

We rely on your consent to collect, use and disclose your personal data, except where collection, use or disclosure without consent is permitted or required under the PDPA or other written law (for example, under the deemed-consent provisions, the legitimate-interests or business-improvement exceptions, or where the data is publicly available).

6.1 Withdrawing consent

You may withdraw your consent to our continued collection, use or disclosure of your personal data at any time by contacting our Data Protection Officer (see Section 15), giving reasonable notice. Upon receiving your request, we will inform you of the likely consequences of withdrawal. Please note that withdrawing consent may mean we are no longer able to represent you for opportunities or provide certain services. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and we may continue to retain data where permitted or required by law.

Under PDPC guidance, organisations are generally not permitted to collect, use or disclose NRIC or FIN numbers (or to retain copies of NRICs/FINs) except where (a) it is required under the law, or (b) it is necessary to accurately verify identity to a high degree of fidelity. There is no legal requirement to provide an NRIC or FIN number for the purpose of a job application.

Accordingly:

• We do not require your NRIC/FIN number, or a copy of your NRIC/FIN, when you apply for a role or register with us.
• Where a role requires background screening that must rely on your NRIC/FIN as an identifier, we will collect it only with your consent and only to the extent necessary for that verification.
• Where you are successfully placed and accept an offer, your NRIC/FIN may be collected to comply with statutory record-keeping obligations (for example, under the Employment Act) or other applicable law.
• We apply enhanced safeguards to any national identification numbers we hold, restrict access to them, and cease to retain them once they are no longer required for legal or business purposes.

We may disclose your personal data, on a need-to-know basis and subject to appropriate safeguards, to:

• Prospective employers and clients: to present your candidacy for relevant roles (we will not submit your profile to a specific client without your agreement);
• Background-screening and reference providers: engaged to carry out checks relevant to a role;
• Service providers and data intermediaries: such as IT, cloud hosting, applicant-tracking and communications providers that process data on our behalf under written contracts requiring PDPA-comparable protection;
• Professional advisers: such as legal, accounting and audit advisers, where necessary;
• Public authorities: where required or permitted by law, or in response to a lawful request; and
• Successors: in connection with a corporate transaction such as a merger, acquisition or restructuring.

We do not sell your personal data. Where we engage data intermediaries, they are permitted to process your personal data only for the purposes we specify and in accordance with our instructions.

We may transfer your personal data to, or store it in, locations outside Singapore in the course of providing our services or where our service providers are located overseas.

Where we do so, we will take steps required under the PDPA to ensure that the overseas recipient is bound by legally enforceable obligations to provide a standard of protection comparable to that under the PDPA (for example, through contractual clauses), or rely on another basis permitted under the PDPA (such as your consent to the transfer after being informed of the risks).

We retain your personal data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required for our legal or business purposes. We cease to retain personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that retention no longer serves those purposes.

Our indicative retention periods are:

We implement reasonable administrative, physical and technical security measures to protect your personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These include access controls, role-based permissions, encryption, secure storage, staff training and confidentiality obligations. While we take care to protect your personal data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Subject to the PDPA, you have the following rights in relation to your personal data:

12.1 Access and correction

You may request access to the personal data we hold about you and information about how it has been used or disclosed in the year before your request. You may also request correction of any error or omission. We will respond to your request as soon as reasonably possible (and ordinarily within 30 days; if we cannot, we will let you know when to expect a response). A reasonable fee may apply to an access request, and we may decline a request where permitted under the PDPA, in which case we will tell you why.

12.2 Withdrawal of consent

You may withdraw consent for the continued use or disclosure of your personal data at any time, as described in Section 6.

12.3 Data portability

Where and when the PDPA's data portability provisions come into force, you may request that certain personal data we hold about you be transmitted to another organisation in a commonly used machine-readable format, subject to the conditions set out in the PDPA and its regulations.

To exercise any of these rights, please contact our Data Protection Officer (Section 15). We may need to verify your identity before acting on your request.

Our website uses cookies and similar technologies to enable core functionality, remember your preferences and understand how the site is used. We may collect technical data such as your IP address, browser type, device information and pages visited. You can control or disable cookies through your browser settings, although some features of the site may not function properly as a result.

We maintain procedures to detect, assess and respond to data breaches. Where a data breach is assessed to be notifiable under the PDPA (because it is likely to result in significant harm to affected individuals, or is of a significant scale) will require us to notify the PDPC, and the affected individuals where required, in accordance with the timeframes and requirements under the PDPA.

We may update this Privacy Notice from time to time to reflect changes in our practices or in the law. The current version, with its effective date, will always be available on our website. We encourage you to review it periodically. Material changes will be communicated through the notice on our website.

If you have any questions about this Notice, wish to exercise your rights, or have a complaint about how we handle your personal data, please contact our Data Protection Officer (“DPO”):

Name / title

Ong Jun Kiat (Data Protection Officer)

Email

junkiat.ong@talentfirst.com.sg

Telephone

+65 8778 1088

Mailing address

6 Battery Road #03-315, Singapore 049909

If we are unable to resolve your concern to your satisfaction, you may lodge a complaint with the Personal Data Protection Commission. Information is available at www.pdpc.gov.sg.

This Privacy Notice is governed by and construed in accordance with the laws of Singapore.