Recruitment Data Privacy Policy

• This Policy defines the collection, storage, use and disclosure of your personal data by Swire Shipping Pte Ltd and all its subsidiaries (hereinafter collectively referred to as the “SS Group“, “we” or “us“) throughout the recruitment process.
  It sets out your rights and explains who you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
  This Global policy only applies to the personal data of job applicants and potential candidates for employment. It does not apply to our employees, contractors or clients, or other personal data that the SS Group collects for other purposes.
  Each SS Group company acts as the data controller for personal data collected for its own recruitment purposes.

• Definitions

  DPO	SS Data Protection Officer: Mike Gerasymov Tel: +65 6603 9452 dataProtection@swireshipping.com
  Personal Data / Personal Information	Has the meaning given to it in the Applicable Data Protection Legislation. In some jurisdictions, Personal Data includes any information relating to an individual from which that person can directly or indirectly be identified. However, in other jurisdictions, “business contact information” (unless provided by the individual solely for his or her personal purposes) is not considered Personal Data.
  Process	The collection, use, amendment, storage, transmission, disclosure, transfer, retention, erasure or any other handling or treatment of Personal Data by the Company.

• Information we collect about you

  This information will include your personal data, which means information that can be used to identify you, which may include but not be limited to the following, as well as any other information about you that you disclose to us during the application process:
   

  PERSONAL DATA collected

  LEGAL GROUNDS of processing

  Personal information such as: Your name, address and contact details. Your nationality, date of birth, marital status, place of residence. Social security number, passport number or other national identification numbers. Prior work experience information such as: CV, employment history, reference information and/or information received from background checks (where applicable). Such information may be provided to us by third parties e.g. recruiters. Professional qualifications and certificates. Education history and transcripts. Information from interviews.

  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). For our legitimate business interests. To comply with applicable laws, regulations, legal processes or governmental requests – these may include but are not limited to minimum age labour laws, local content or employment requirements. 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 would require and the reason we need it, so that you can carefully consider whether you wish to consent.

   

  If you fail to provide us with this information, or you object to us processing such information (see section 5.6 below for more information about your rights in relation to your information) the consequences are that we may be prevented from progressing your application.

• How we collect information about you

  We collect your personal data when you submit a job application or CV to us.
  In considering your application we may also obtain information from third party sources, including any referees that you specify, educational institutions and 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 SS Group and you can subsequently opt-out at any time by contacting the SS DPO by emailing DataProtection@swireshipping.com.
  Your personal data may be provided to the SS Group by recruitment agencies with whom you have registered an interest in working for the SS Group or by background check agencies.
  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 consents from that individual to do so on their behalf.
  If you are a recruitment agency you should, in particular, make sure that all of the information in this Privacy Notice is communicated to the applicant.

• What we do with the information we gather

  The SS Group may use the information and opinions collected through the recruitment process (including but not limited to setting up and conducting interviews and tests and bevaluating and assessing the results) for the following purposes:

  • to consider and process any application that you make for any particular job with the SS Group including to identify and contact you;

  • to determine whether you have the professional skills, expertise and experience for the position applied for;

  • if you are offered a position with the SS Group, to verify the personal data provided including your identity, address, right to work, employment history and academic background and other background screening purposes;

  • to communicate with you about the recruitment process and/or your application;

  • to determine the terms on which you may work for the SS Group (where applicable);

  • to assist in the administration of the SS Group’s recruitment programme and compliance with related internal policies (such as our equal opportunity, modern slavery and human trafficking policies);

  • to provide you with information about other job vacancies if you would like the SS Group to send you such notifications; and

  • for statistical purposes.

  If successful in the employment process any information provided through the recruitment process may form the basis of your personnel record with the SS Group and may be used for the purposes of administering your employment, benefits and training with the SS Group, ensuring your health and safety and to fulfil the SS Group’s responsibilities as an employer. You will receive further information about such processing as applicable.

• Sharing your information

  In order to consider any application that you make to SS Group, we may transfer your personal information to countries outside of the country in which you are resident, including:

  • third party service providers for verification of your work experience, qualifications and background;

  • any referees indicated in your CV or during your job application or interview; and

  • SS Group offices in different jurisdictions.

  You should be aware that in different jurisdictions, data privacy 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 safeguards in place to protect your personal data that comply with our legal obligations.

  We may also share your personal information with:

  • law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and

  • other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

  Except as indicated above, your details will be accessible only by our authorised personnel and will not be disclosed to any third party. The information we hold is not traded with any external bodies or organisations and is not used for marketing purposes.

• How long do we retain your personal data

  If your application for employment is unsuccessful then we may continue to hold information and opinions about you and your applications after any application process is complete, in case we need to consult it in the future if you make another application or become a SS Group employee, if a dispute arises about an application that you have made or in order to contact you if potentially suitable job opportunities become available in the future.
  Your personal data will not be retained for longer than is reasonably required for the relevant purposes for which it was collected, or as otherwise permitted by applicable law.

• Your rights

  Under certain circumstances and to the extent such rights are granted under applicable data protection legislation, you have the right to:

  • request access to your personal data (commonly known as a data subject access request);

  • request the correction of your personal data;

  • request the erasure of your personal data;

  • object to the processing of your personal data;

  • not be subject to a decision based solely on automated processing;

  • request that the processing of your personal data is restricted;

  • request the transfer of your personal data to another controller; and

  • request the withdrawal of any consent that you have given for the processing of your personal data unless there is another lawful basis for the continued processing of that data.

  You should be aware that not all of these rights are absolute and there may be circumstances in which the SS Group will not fully comply with your request because of a specified legal ground or exemption.

  If at any stage you would like to withdraw an application or remove your CV and/or details from our systems, exercise any of the above rights, or if you wish to raise a complaint about how we are using your personal data or you do not wish us to contact you in relation to future employment opportunities, please let us know by contacting the SS DPO by emailing DataProtection@swireshipping.com.

  If you have any concerns about our use of your information, you also have the right to make a complaint to your local data protection regulator.

• Automated processing

  The SS Group does not carry out automated decision-making or profiling in relation to your personal data.

• Changes to Policy

  SS reserves the right to amend this Policy at its sole discretion. In case of amendments, the Policy owner will inform staff appropriately.