Dear Employees,

The PDPA came into effect recently on 2 July 2014. Under the PDPA, organizations are required to observe and comply with the various requirements that regulate the collection, use and disclosure of  personal data of  an individual (“Individual”) and recognize the right of the Individual to the protection of their personal data.  The Company respects the confidentiality of personal data. We have a Privacy Policy that applies to how we may collect, use or disclose your personal data.

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About this Privacy Policy

This Privacy Policy informs you about the Company’s policy and practices on data privacy matters which relate to you.  In the event of any conflict between the English version and other language versions of this Privacy Policy, the English version shall prevail.

In this Privacy Policy, we will tell you:

• what personal data is collected;
• the purposes for which the Company uses your personal data;
• whom your personal data may be disclosed to;
• your rights over your personal data;
• how and who to contact in the Company with regard to any matter relating to your personal data.

1) Source of your personal data

We may collect personal data directly from you, whether in writing such as when you fill up an application form for employment purposes or verbally. We may also verify or source personal information about you from both public and private third party sources such as credit reporting agencies, recruitment agencies, agencies that administer benefits or payroll or other services for employment purposes on behalf of the Company social media or websites, if applicable to the particular purpose of your employment with the Company.

2) What personal data is collected 

Generally, basic personal data that identifies you may be collected and processed by us at the start of your job application, throughout and after your employment with the Company and from time to time, thereafter. Specific personal data may be required and collected from you or third party sources for certain dealings, transactions or activities and for risk/fraud management. We may collect such data including, but not limited to the following:

• Identification Information: name, date of birth, nationality, gender, National Registration Identification Card or passport number, marital status, family and dependents details, correspondence address, contact details including mobile  and residential telephone number and facsimile number, personal e-mail address and emergency contact information;
• Employment-related Information: work and salary history, resumes, curriculum vitae, academic  or professional qualifications, employment history, knowledge, experience and expertise, employment references and personal background verification; 
• Financial data: bank account numbers, salary-related information, tax-related information or  information on  financial or credit worthiness; 
• Sensitive Personal Information: any information as to the physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any offence. 

Third party sources from whom the Company may either collect or seek verification of your personal data, include but are not limited to the following:

• your current or previous employer in relation to your income or any related data; and
• credit bureaus or agencies which provide credit or other information;
• public bodies (such as the  Accounting and Corporate Regulatory Authority, Immigration & Checkpoints Authority, Insolvency and Public Trustee’s Office, Inland Revenue Authority of Singapore or Singapore Land Authority.)

If you are a  minor under 18 years of age,  before you submit personal data to the Company, please forward us the written consent of your parent/s or legal guardian to the collection, use or disclosure of your personal data and their  and their  acceptance and agreement to be bound by this Privacy Policy and to be  responsibility for your  actions.

3) What are the purposes for which the Company uses your personal data

The Company collects, processes and retains your personal data for purposes in connection with your employment with us, such as:

• to verify your identity;
• for administrative purposes pertaining to all aspect of your employment with us including file management, reporting, audits, data maintenance and security;
• to respond to your enquiries, feedback or complaints and for emergency and safety purposes, including for monitoring access to the workplace, related facilities and systems;
• to cover you, your spouse(s) and children for medical and/or hospitalization insurance under the Company’s policy; 
• to cover you for group personal accidents, group term life insurance under the Company’s policy and for direct banking in relation to  insurer outpatient claims;
• to perform other administrative and operational tasks (including but not limited to staff training, recruitment, market or customer surveys, service improvement and product development);
• to handle enquiries, audit, complaints or legal proceedings;
• to prevent or investigate any fraud or crime or suspected fraud or crime, including internal investigations; and
• to adhere to any  requirements set by the relevant laws and regulations.

The provision of your personal data in the employment application form or as may be required by the Company from time to time for any specific purpose is mandatory for purposes of your employment but if you do not provide such personal data, the Company will not be able to process your personal data for the purposes described herein. 

4) Classes of Persons whom your personal data may be disclosed to

We may use your personal data to perform functions including data processing or data storage, which may involve sharing your personal data with third parties. These are the classes of persons to whom we may need to disclose your personal data:- 

• the Company’s data processors or service providers, within and outside  Singapore, engaged  to carry out certain functions and activities of the Company;
• the Company’s professional advisors and external auditors; 
• the Company’s related and associated companies, within and outside Singapore, their assignees or potential assignees, acquirers or potential acquirers and successors-in-title;
• regulatory bodies, government agencies, the police, law enforcement bodies and courts, both within and outside Singapore;
• other affiliate companies  both within or outside Singapore; 
• your referees and persons who introduce you to the Company;
• your authorised agents, executor, administrator or legal representative;
• the Company’s assignees or potential assignees, acquirers or potential acquirers and successors-in-title or other third parties in connection with a corporate transaction such as a sale of a subsidiary or division, merger, consolidation or asset sale; and
• such persons or bodies to whom the Company is legally required to disclose.

5) Your rights over your personal data

The accuracy and completeness of your personal data depends on the information you provide. We assume that the information you have provided is accurate, up to date and complete unless you inform us otherwise. In circumstances where you provide any third party information to us including but not limited to employer, colleagues, family information, we assume that such information is accurate, up to date and complete and that you have obtained the necessary consent to disclose the same.

You may at any time give the Company reasonable notice of any consent  given, or deemed given under the PDPA, in respect of the collection, use or disclosure by us of your personal data for any purpose.  Upon such notification from you, we will inform you of the consequences of your withdrawal of consent to the collection, use or disclosure by us of your personal data.

The Company will take reasonable steps to keep employee records complete, accurate and up-to-date. We will use appropriate measures to safeguard personal data of employees against loss, misuse, unauthorized access, theft, disclosure or destruction. 

6) How to contact the Company

The Company’s Human Resource Department is responsible for the implementation and administration of this Privacy Policy. Strict adherence to this Privacy Policy is necessary. All employees of the Company whose responsibilities include the processing of personal data are required to strictly comply with this Privacy Policy, failing which disciplinary action may be taken by the Company.

If you believe that your records with us are inaccurate, incomplete or not updated, or if you wish to request for access or correction of your personal data or make inquiries or complaints regarding our personal data, please contact the Human Resource Department by writing in to us at the following address, upon which we will promptly rectify. 

Address to write-in:

Human Resource Department
Colgate-Palmolive (M) Sdn Bhd, 
Jalan Semangat / Jalan Bersatu, 
Seksyen 13, 46200 Petaling Jaya, 
Selangor
Contact Number: 603-7965 4105
603-7965 4117

7) Review of  this Privacy Policy

This Privacy Policy will be reviewed from time to time and changes may  be made to this Privacy Policy to take into account new laws and technology and changes to our business operations and practices.