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Privacy Policy

IPSEM SQUARED HK LIMITED

Privacy Policy for IPSEM Squared Recruitment Website

INTRODUCTION

Like most businesses, we hold and process a wide range of information, some of which relates to individuals who carries out services for us. This Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you as a user of the services provided by IPSEM Squared Recruitment, a part of IPSEM Squared HK Limited (herein referred to as “IPSEM Squared”, “we”, “us”).

The notice focuses on users of the IPSEM Squared Recruitment website (IPSEM Squared Recruit). It also covers information on former users of the site.

This Privacy Notice is set out in this document (the Core Notice) and Annex 1- Supplementary Information. We have also provided the local information, which makes clear any differences in your particular jurisdiction. This can be found in Annex 2.

In the Supplementary Information, we explain what we mean by “personal data”, “processing”, “special personal data” and other terms used in the notice.

In brief, this notice explains:

  • what personal data we hold and why we process it;
  • the legal grounds which allow us to process your personal data;
  • where the data comes from, who gets to see it and how long we keep it;
  • how to access your personal data and other rights;
  • how to contact us.

PERSONAL DATA - WHAT WE HOLD AND WHY WE PROCESS IT

We process data for the purposes of our business including management, administrative, and legal purposes. The Supplementary Information provides more specific information on these purposes, on the type of data that may be processed and on the grounds on which we process data.  See Legal grounds for processing personal data and Further information on the data we process and our purposes.

WHERE THE DATA COMES FROM AND WHO GETS TO SEE IT

Some of the personal data that we process about you comes from you. For example, you tell us your contact and previous work details.

Other personal data about you is generated in the course of your work, for example, from IPSEM Squared’s staff members.

Your personal data will be seen by IPSEM Squared’s staff members, in particular, managers and HR. We will where necessary and as set out in this privacy notice also pass your data outside the organisation, for example when dealing with companies who are seeking candidates.

Further information on this is provided in the Supplementary Information. See Where the data comes from and Who gets to see your data?

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your engagement with IPSEM Squared and for a period afterwards.

See Retaining your personal data more information in the Supplementary Information.

TRANSFERS OF PERSONAL DATA OUTSIDE HONG KONG

We will where necessary and as set out in this privacy notice transfer your personal data outside Hong Kong to any Group Company (defined below) and processors in other jurisdictions in which we are established. For the purpose of this privacy notice, “Group” means IPSEM Squared and any holding company or subsidiary of IPSEM Squared from time to time and any subsidiary of any holding company of IPSEM Squared. “Holding company” and “subsidiary” shall have the meanings given to them in the Hong Kong Companies Ordinance. “Group Company” shall mean any company within the Group.

Further information on these transfers and the measures taken to safeguard your data are set out in the Supplementary Information under Transfers of personal data outside Hong Kong – more information.

A list of data recipients who receive material amounts of personal data and are located outside of the Hong Kong is set out in Annex 3- Extra-Hong Kong Third Party Processors.

YOUR DATA RIGHTS

You have a right to make a subject access request to receive information about the data that we process about you. Further information on this and on other rights is in the Supplementary Information under Access to your personal data and other rights. We also explain how to make a complaint about our processing of your data.

CONTACT DETAILS

In processing your personal data, we act as a data controller.  Our contact details are set out in Annex 2.

Please note that generally the data controller of your personal data will be your engaging entity (i.e. IPSEM Squared) but also entities within the Group with which we share data for business administration purposes.

STATUS OF THIS NOTICE

This notice forms part of your engagement agreement and creates contractual rights or obligations. It may be amended by us at any time.

 

ANNEX 1

SUPPLEMENTARY INFORMATION

WHAT DO WE MEAN BY "PERSONAL DATA" AND "PROCESSING"?

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.

Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV or photographs.

"Processing" means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by UK and EU privacy law to be “special personal data”.

LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

WHAT ARE THE GROUNDS FOR PROCESSING?

There are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.

Term

Ground for processing

Explanation

Contract

Processing necessary for performance of a contract (i.e., your usage agreement with IPSEM Squared) with you or to take steps at your request to enter a contract

This covers carrying out our contracted duties and exercising our contractual rights.

Legal obligation

Processing necessary to comply with our legal obligations

Ensuring we perform our legal and regulatory obligations.

Legitimate Interests

Processing necessary for our or a

third party’s legitimate interests

We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

Your data will not be processed on this basis if our or a third party’s interests

Consent

You have given specific consent to processing your data

In general, processing of your data in connection with your engagement is not conditional on your consent. But there may be occasions where we do specific things such as getting a criminal record check for a role which is regulated and rely on your consent to our doing so.

PROCESSING SPECIAL PERSONAL DATA

If we process special personal data about you (for example (but without limitation), storing your health records to assist us in ensuring that we provide you with a healthy and safe workplace or processing personal data relating to diversity monitoring), as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing special personal data applies. In outline, these include:

  • Processing being necessary for the purposes of your or our obligations and rights in relation to your engagement in so far as it is authorised by law;
  • Processing relating to data about you that you have made public (e.g. if you tell colleagues that you are ill);
  • Processing being necessary for the purpose of establishing, making or defending legal claims;
  • Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
  • Processing for equality and diversity purposes to the extent permitted by law.

FURTHER INFORMATION ON THE DATA WE PROCESS AND OUR PURPOSES

The Core Notice outlines the purposes for which we process your personal data. More specific information on these, examples of the data and the grounds on which we process data are in the table below.

The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention data relating to criminal offences, if we were to find out that someone working for us was suspected of committing a criminal offence, we will process that information if necessary for our purposes. If necessary we will also require criminal background checks for certain roles – for example those working in financial roles or working with minors.

Purpose

Examples of personal data that may be processed

Grounds for processing

Recruitment

Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality, contact details, summary of skillset, professional experience and education (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous engagement details), financial information (including current service salary information) language skills, details as to availability and IPSEM Squared’s assessment as to your suitability to various roles, and any other personal data that you present us with as part of your application related to the fulfilment of the role.

Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work.

Information such as your salary and expenses.

If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.

Contract

Legal obligation Legitimate interests

Physical and system security

Records of your use of our systems.

Legal obligation Legitimate interests

Improving efficiency of IT and business systems and device use

Records of your use of IT and business systems provided by IPSEM Squared.

For example, we may collect information on the number of minutes and amount of activity while using IPSEM Squared web-based services.

We will where necessary and as set out in this privacy notice also contract with third parties to provide our services.

Such applications will process your personal data. Their own privacy notices will make clear precisely what information will be collected. We may be provided with information on the usage of such applications, for example for the purpose of troubleshooting or assessing overall usage and whether to continue to provide them.

Legitimate interest

Providing information to third parties in connection with transactions that we contemplate or carry out

Information on your contract and other data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer.

Legitimate interests

Monitoring of diversity and equal opportunities

Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymized diversity statistics with regulators if formally required / requested.

Legitimate interests

Monitoring and investigating suspicions of misconduct, compliance with policies and rules

– both generally and specifically

We expect you to comply with our policies and rules and may monitor our systems to check compliance. We will where necessary and as set out in this privacy notice check system and other data to look into those concerns (e.g., log in records and records of usage). In appropriate cases if we have suspicions of serious wrong-doing, we may make targeted records (e.g. video or sound) in connection with an investigation.

Legitimate interests

Disputes and legal proceedings

Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.

Legitimate interests Legal obligation

Maintaining appropriate business records during and after your engagement with us

Information relating to your usage of IPSEM Squared services which are relevant to such records.

Contract Legal obligation Legitimate interests

WHERE THE DATA COMES FROM

When you start engagement with us, the initial data about you that we process is likely to come from you: for example, contact details. We will where necessary and as set out in this privacy notice also require references and information to carry out background checks. In the course of engagement, you may be required to provide us with information for other purposes. If you do not provide information that you are required by statute or contract to give us, you may lose access to our services. If you have concerns about this in a particular context, you should speak to HR.

In the course of your work, we may receive personal data relating to you from others. This may be derived from the relevant company with whom you have been connected for the purposes of finding employment or those with whom you communicate by email or other systems.

WHO GETS TO SEE YOUR DATA

INTERNAL USE

Where necessary and as set out in this privacy notice, your personal data will be disclosed to IPSEM Squared’s staff members, including HR and administrators for administrative and management purposes as mentioned in this document. We will where necessary and as set out in this privacy notice also disclose this to other companies of the Group.

EXTERNAL USE

We will only disclose or transfer your personal data outside the Group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.

We will disclose or transfer your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). Where necessary, we will also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.

Specific circumstances in which your personal data may be disclosed/transferred include:

  • Transfer to the clients of IPSEM Squaredenabling them to assess your skillsets, availability and suitability to various roles, and reach out to you if they would like you to provide services to them directly in future;
  • Disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
  • Disclosure on a confidential basis to a potential buyer of our business or company for the purposes of evaluation – but only if we were to contemplate selling;
  • Disclosure to respond to law enforcement agency requests or where required by applicable laws, pursuant to court orders, or arbitral or tribunal orders or rules of procedure, or to government regulations departments or agencies or regulatory bodies (including disclosures to tax authorities), and any other regulatory bodies);
  • Disclosure on a confidential basis to our advisers for example to our lawyers for the purposes of seeking legal advice or to further IPSEM Squared’s interests in legal proceedings and to our accountants for auditing purposes;
  • Disclosure to our insurers;
  • Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request;
  • To third parties for the purpose of assessing efficiency of IT or business system device usage. In such cases the data sent to the third party will be anonymised where possible.

RETAINING YOUR PERSONAL DATA - MORE INFORMATION

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your engagement with IPSEM Squared and for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your engagement either as a record or in the event of a legal claim.

If your data is only useful for a short period we will delete it.

TRANSFERS OF PERSONAL DATA - MORE INFORMATION

In connection with our business and for administrative, management and legal purposes, we will where necessary and as set out in this privacy notice transfer your personal data outside Hong Kong to any Group Companies and on occasion other jurisdictions in which we are established. We will ensure that any transfer is lawful and that there are appropriate security arrangements.

In relation to intra-group transfers, the Group Companies have entered into an intra-group data sharing agreement ensuring appropriate and suitable safeguards with IPSEM Squared’s controllers/processors outside Hong Kong. These are in standard terms approved by the European Commission. If you wish to see details of these safeguards, please ask our Information Security Officer.

A list of data recipients who receive material amounts of personal data and are located outside of Hong Kong is set out in Annex 3- Extra-Hong Kong Third Party Processors.

ACCESS TO YOUR PERSONAL DATA AND OTHER RIGHTS

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:

  • Giving you a description and copy of the personal data
  • Telling you why we are processing it

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank details), you have the right to be given the data in a machine-readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.

If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

COMPLAINTS

If you have complaints relating to our processing of your personal data, you should raise these with the Information Security Officer in the first instance. You may also raise complaints with your statutory regulator.  For contact and other details ask the Information Security Officer.

STATUS OF THIS NOTICE

This notice forms part of your engagement agreement and creates contractual rights or obligations. It may be amended by us at any time.

 

ANNEX 2

INFORMATION SPECIFIC TO JURISDICTIONS

HONG KONG

If you are engaged or otherwise in Hong Kong the following additional information applies. The statutory regulator is the Office of the Privacy Commissioner for Personal Data.

Data controller

Address

IPSEM Squared HK Limited

Room 2401, 24/F Dominion Centre

43-59 Queen's Road East

Wanchai,

Hong Kong

 

Information Security Officer

Company

E-mail address

Sharon Nalani

IPSEM Square Operational Services. SDN. BHD.

sharon@ipsemsquared.com

Please note that this Privacy Notice, along with other related IPSEM Squared policies and/or protocols, shall form IPSEM Squared’s policy for processing special data as required by the UK Data Protection Act 2018 (Schedule 1 Part IV).

 

ANNEX 3

EXTRA-HONG KONG THIRD PARTY PROCESSORS

As indicated above, we may transfer your personal data outside Hong Kong.

 The transfer of personal data to recipients based outside of Hong Kong is carried out for administrative and management purposes as mentioned in this document.

 List of data recipients located outside Hong Kong:

Recipients

Country

Keen Steps Inc.

USA, Ireland

IPSEM Squared Operational Services. SDN. BHD.

Malaysia

Shearn Delamore & Co. (Lawyers)

Malaysia