Privacy Policy - your privacy matters

Foremo.st (“Feltan Associates", “we”, “us”, or “our”) is part of Feltan Associates Pte Ltd, an international group of consulting and recruitment services under the styles/brands of "Foremo.st", "Panelli.st", “Search & Counsel” and “Chartered Partners”.

We are committed to protecting the privacy of our candidates, clients and users of our website. Feltan Associates Pte Ltd entity acting as controller of your data will depend on the services we perform for you, as described below.

We want to provide a safe and secure user experience. We will ensure that the data you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this Privacy Policy.

Through this Privacy Policy, we aim to inform you about the types of personal data we collect, the purpose for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the Personal Data Protection Act 2012 (No. 26 of 2012) ('PDPA'); the Personal Data Protection (Amendment) Act 2020 ('the Amendment’) and other relevant laws and regulations.

1. Scope

Protecting your personal data is our priority. This Privacy Policy explains how Search & Counsel processes and protects personal data about:

• candidates who register with us for roles that we are managing for other employers and for roles at Search & Counsel, or through our website, job boards, social media sites or other sources;

• prospective candidates,

• business contacts at our clients and suppliers; and

• users of our websites; (collectively “you” or “your”)

It also tells you about your privacy rights including your right to object to our processing. If you would like to contact us, please see the “How to contact us” section of this policy.

2. Personal data we collect

Candidates

When you register with us as a candidate to provide work finding services to you, you provide and we process your personal data, including but not limited to your name, contact details and data from your CV, current benefits and your expectations for future roles. Where permitted by law, we may also collect data relating to your health (for example, disability data for reasonable work adjustment purposes), diversity data, including race, ethnic origin, sexual orientation and religion (for equal opportunity monitoring purposes) as well as details of any unspent criminal convictions where required by a client or by us if you apply for a role with us. 

If you use our website, click on links in emails we send to you, open or forward them, or sign up to receive job alerts or other content from us, we also collect personal data from those interactions. 

We also obtain personal data about you from third parties, including:

• referees – when you are offered a job;

• former employers – to confirm dates of employment;

• educational institutions – to check your academic qualifications;

• background checks – if we need to obtain details of unspent criminal convictions or confirmation that there are none to the extent permitted by law;

• credit reference agencies – if we need to check your financial standing;

• publicly available sources such as LinkedIn and social media sites to enhance the data we hold about you, in order to help us find more suitable roles for you;

• clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV.

Prospective Candidates

We collect personal data about you, including your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn and social media sites, so that we can contact you if we think you may be interested in our work finding services at a future date. We may also obtain your personal data through another candidate or an employer who recommends you as a contact.

Prospective Business Clients

We collect your contact details and data relating to your function or position to establish commercial relationships with your company.

Users of our website or apps

We collect personal data such as your IP address and other data about your device which we need to provide our online content to you. We also collect data about your engagement with our website or apps such as the pages you view. If you contact us, we will also collect data about your enquiry. We use cookies and similar technologies to collect a lot of this data and our cookie policy tells you more about this.

Clients

We collect personal data such as your name, job title and contact details. We also process personal data about what communications we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent to you. We also process feedback that you provide about our candidates.  

If you provide information to us about a candidate (for example, if you confirm a candidate has worked with you or if you provide a reference), then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to us about that candidate. 

We process personal data about you from public domain sources such as LinkedIn and social networking sites or because you were a delegate at one of our events or at an event where the event organizer is permitted to share delegate details with us.

Suppliers

We collect your name and contact details as a business contact for your organization.

3. Providing your personal data

In some cases, it will be necessary for you to provide personal data to us for us to work together. If you do not provide us with the personal data we request for, we may not be able to provide you with our services effectively.

4. How we use your personal data

Candidates

We use your personal data to:

• provide you with work finding services;

• communicate with you;

• enable you to upload your CV and apply for jobs;

• personalise your experience by creating a candidate profile; 

• enable us to monitor equality and diversity;

• provide you with interviewing and salary advice and

• send you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices.

We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest. We target these ads based on your previous interactions with our website, emails and through your engagements with our consultants. Your interaction with our ads may be used to measure the effectiveness of our ad campaigns and to improve our marketing strategy. This processing is carried out via Cookies and only if you have previously provided consent.

Prospective Candidates and Business Clients

We use your personal data to:

• determine if you may be interested in our services and how we can assist you;

• to contact you and find out if you are interested in our services.

Users of our website or apps

We use your personal data to:

• improve and personalize your experience when you use our website or apps; and

• personalize advertising you received from us.

Clients

We use your personal data:

• to provide recruitment services to you;

• to communicate with you;

• to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;

• to maintain our business relationship with you;

• to answer your enquiries when you contact us;

• to fulfil contractual obligations to you;

• to establish, exercise or defend legal claims; and

• for direct marketing purposes.

Suppliers

We use your personal data:

• to communicate with you;

• to maintain our business relationship with you;

• to answer your enquiries when you contact us;

• to fulfil contractual obligations to you;

• to establish, exercise or defend legal claims; and 

• for direct marketing purposes.

You can unsubscribe from receiving marketing communications from us, using the unsubscribe methods contained in communications we send to you or by contacting us.

5. Legal grounds for processing your personal data

Under the Regulation and other applicable laws, we rely on the following grounds to process your personal data:

(a) Performing a contract – where, in order to perform our obligations under a contract with you or take steps at your request to enter into a contract with us, it is necessary for us to process your personal data;

(b) Compliance with legal obligations – where we need to process your personal data to comply with legal or regulatory obligations;

(c) Our legitimate interests or those of a third party – including:

• providing our services to you;

• responding to your requests and enquiries (the legitimate interest of the companies in this case is to maintain a constant and updated communication with clients and candidates, which is part of any commercial relationship);

• optimizing the performance of our website and user experience;

• informing you about our services such as job opportunities, industry reports and insights, events, promotions and competitions (the legitimate interest of Search & Counsel is to inform clients and candidates about similar services and products);

• ensuring that our operations are conducted in an efficient manner;

• providing satisfaction surveys of our services; and

• contacting prospect business clients in order to establish commercial relationships with business clients (the legitimate interest of Search & Counsel is to maintain relations of any kind with the company where the contact person works).

(d) Consent – in some circumstances, we will ask for your consent to process your personal data in a particular way – to manage your marketing preferences. For example, if you register for a job, we will offer you the possibility of registering for similar job alerts. To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. Please see the “How to contact us” section of this policy, if you would like to withdraw your consent.

6. Automated decision making

We do not take decision based solely on automated processing; there is always human intervention before making and taking a decision.

We perform one type of profiling based on candidate’s personal data: Intelligent search within our customer database enables us to filter through CVs when we receive many applications for roles that we advertise, and to enter relevant key words such as years of experience or field of practice. It then analyses all the CVs uploaded into it and delivers a smaller pool of candidates by matching the key words in candidates’ CVs and ranking the candidates according to their suitability for the role. As explained above, there is always a recruiter who verifies this process, so there are not automated decisions.

Please note, the above profiling activities produce legal or similar significant effect to candidates, however if you would like to know more, please contact us.

7. Who we share your personal data with

While your personal data will be kept confidential, in certain circumstances, it may be necessary for us to provide or disclose your personal data if required for any of the foregoing purposes. Where we do so, we would merely disclose data that is necessary for the purpose of such disclosure.

Other companies within our Group

Search & Counsel is part of Feltan Associates Pte Ltd which operates globally. Our recruitment experts and key members of the business who run functions such as payroll, IT support might be based all around the world. We may share with or give access to your personal data to other companies within Feltan Associates Pte Ltd.

The purposes of sharing your personal data within Feltan Associates companies are: (i) providing essential services which are centralized in one single entity such as IT, commercial and sales support services, in this case these entities will access and process your personal data as data processors, following the instructions of your data controller, (ii) managing global, regional or senior executive positions, or the development of key accounts, which would require the cooperation of different companies across the group, and (iii) managing positions that can be fulfilled remotely.

The applicable lawful basis to these processing activities is the performance of the contract with clients and candidates or to take steps necessary to enter into a contract, and the legitimate interests of Feltan Associates Pte Ltd in delivering its services using internal resources.

Third parties

If you are a candidate, we share your personal data with clients who have vacancies for jobs which you are interested in.

We also share your personal data and where necessary, special category data with third party services who perform services and functions on our behalf, such as:

• conducting employment reference checks;

• conducting qualification checks;

• carrying out criminal convictions checks (as required);

• verifying details you have provided from third party sources; 

• conducting psychometric evaluations or skills tests;

• hosting personal data for us;

• providing professional advice to us;

• providing data analytics to us;

• carrying out testing and development work on our business technology systems;

• administering surveys or competitions on our behalf; 

• assisting us to communicate with you; and

• providing research and mailing house or other direct marketing services.

We contractually require minimum standards of confidentiality and data protection from our third-party service providers.

8. Other disclosures

In addition, we may disclose your personal data:

• if we are legally required to do so;

• to law enforcement agencies, regulators or other government officials; and

• to the new business owners and their advisers in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business

Keeping your personal data secure

We have implemented and maintain appropriate technical and organizational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. Only authorized personnel and third-party service providers are provided with access to personal data on a need-to-know basis, and these employees and service providers are contractually obliged to treat this data as confidential.

How long we hold your personal data for

We will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for, which may be an ongoing purpose. For example, if you’re a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers.

We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorized use or disclosure of your personal data.

Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.

Your rights in relation to personal data we hold about you

You have several rights under the Regulations and other relevant laws. These rights include the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data; to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete data which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of any relevant exemptions we are relying on when we respond to your request.

9. How to contact us

You can contact our Privacy Officer by writing to us at our email address or postal address below, if you wish to request for access to your personal data held by us, request that your personal data be updated or corrected, or withdraw your consent to the processing of your personal data by us. If you would like to have any further data, or if you have any comments about this Privacy Policy or any questions or complaints on any privacy issue, this should also be communicated to us in the same manner.

Contact details: Privacy Officer

Email: [email protected]

Post:

The Data Privacy Officer

Feltan Associates Pte Ltd

One Raffles Place

#02-01 One Raffles Place Mall,

Singapore 048616

10. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time without prior notice to you. We suggest that you visit our website regularly to keep up to date with any changes.