Last updated April 2023

Last reviewed April 2023

Requirement for Employment agencies in Singapore to report NRIC/FIN numbers to MOM

Please note that under the EALCs (Employment Agencies Licencies Conditions) Employment agencies must collect the personal data (e.g. NRIC or FIN numbers) of any jobseekers referred to employers for permanent or contract job positions of at least six months with a fixed monthly salary of $3,300 and above and submit the information to the Ministry of Manpower. This is a regulatory requirement that must be complied with by all licensed Employment Agencies.

https://www.mom.gov.sg/faq/submit-quarterly-referral-and-placement/are-employment-agencies-allowed-to-collect-personal-data

We would like to confirm that this information will not be passed to any other parties, including the end employer.

Full policy

33 Talent (”We”) are committed to protecting and respecting your privacy.

Our Group includes our ultimate holding company and its subsidiaries, including 33 Talent Pty Ltd, 33 Talent Singapore Pte Ltd, and 33 Talent UK Ltd. This notice together with our website terms of use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

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In the UK and EU

 The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

In Singapore 

The Personal Data Protection Act 2012 governs the collection, use and disclosure of personal data by organisations

We are committed to offering our clients and candidates the highest standards of data protection globally.

 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 For the purposes of data protection legislation in force from time to time the data controller is 33 Talent Singapore Pte Ltd of 9 Battery Road, Singapore, 049910.

 Our nominated data protection representative is Gemma Hills.

 

Who we are and what we do

We are a recruitment agency and recruitment business We also provide the following other services: training, talent and HR consultancy, payroll and invoicing management and employment pass applications. We collect the personal data of the following types of people to allow us to undertake our business;

  • Prospective and placed candidates for permanent or temporary roles;

  • Prospective and live client contacts;

  • Supplier contacts to support our services;

  • Employees, consultants, temporary workers;

  • People who use our coaching Services

  • Users of our website who download resources or subscribe to our blog

 We collect information about you to carry out our core business and ancillary activities.

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Information you give to us or we collect about you.

This is information about you that you give us by filling in forms on our site www.33talent.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, download any of our resources, and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website

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Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

  •  technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;

  • information about your visit, including [the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

 

Information we obtain from other sources.

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

 We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, search information providers, credit reference agencies, professional advisors, and previous employers. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

 

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways: 

  • To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.

  • To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.

  •  The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies. 

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Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation if we are legally required to hold information on you to fulfill our legal obligations.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

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Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data is described below:

  • As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

  •  In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

  •  To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts to extract market intelligence which will allow us to serve both clients and candidates better.

  •  When a candidate applies for a role, we may also contact them to share other relevant opportunities.

  • To deliver our coaching services our coaching may make notes on the sessions which are only viewable by the coach. 

 

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses we will make of your data:

We will also use your data:

  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  • To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;

  • To notify you about changes to our service;

  • To allow you to participate in interactive features of our service, when you choose to do so;

  • As part of our efforts to keep our site safe and secure;

  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

  • To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do not undertake automated decision making or profiling. We use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process. 

 

Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.

 

​Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

 A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

 We use Google Analytics, which uses cookies to track your movement through our website. The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

 You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

 

Disclosure of your information inside and outside of the EEA

 We will share your personal information with:

Any member of our group both in the EEA and outside of the EEA.

Selected third parties including:

  • clients for the purpose of introducing candidates to them ;

  • candidates for the purpose of arranging interviews and engagements;

  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;

  • subcontractors including email marketing specialists, event organisers, payment and other financial service providers.

  • analytics and search engine providers that assist us in the improvement and optimisation of our site;

  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

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We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

  • If 33 Talent Singapore Pte Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms of business and other agreements; or to protect the rights, property, or safety of 33 Talent Singapore Pte Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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The lawful basis for the third party processing will include:

  • Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;

  • satisfaction of their contractual obligations to us as our data processor;

  • for the purpose of a contract in place or in contemplation;

  • to fulfil their legal obligations.

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Where we store and process your personal data

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. 33 Talent Singapore Pte Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

 

All information you provide to us is stored on our secure cloud systems. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

  • prior to making an introduction we check that we have accurate information about you

  • we keep in touch with you so you can let us know of changes to your personal data

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:

  • the nature of the personal data;

  • its perceived accuracy;

  • our legal obligations;

  • whether an interview or placement has been arranged; and

  • our recruitment expertise and knowledge of the industry by country, sector and job role.

We may archive part or all of your personal data or retain it on our HR and financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. 

Our current retention notice is available upon request.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes. 

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at hello@33talent.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party in certain formats, if practicable.

Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link https://ico.org.uk/make-a-complaint/

​Make a complaint to a supervisory body which in Singapore is the Personal Data Protection Commission https://www.pdpc.gov.sg/Complaints-and-Reviews

 

Access to information

You have the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

A subject access request should be submitted to hello@33talent.com.

 

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

 

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to hello@33talent.com.

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