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Data Protection Notice for Personnel and Job Applicants

Effective Date: 1 April 2023 
Updated as at 1 April 2023

This Notice sets out the basis upon which NEC APAC (“we”, “us”, “our”) may collect, use, disclose or otherwise process personal data of Personnel and job applicants in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.


  • 1.

    This Notice applies to all full-time, part-time and temporary employees, contract workers and indirect staff of NEC APAC, such other persons engaged by us to perform duties or functions for us, and interns and trainees working at or attached to us (collectively referred to as “Personnel”) as well as persons who have applied for any such position with us (“job applicants”), and all references to “employment” shall apply equally to any and all Personnel.

  • 2.

    As used in this Notice, “personal data” has the same meaning as that defined in the PDPA.


  • 3.

    We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law). We may in exceptional circumstances, rely on consent given on behalf of the individual, for example, by a Personnel on behalf of a family member.

  • 4.

    If you are a job applicant or a Personnel (whether past or present), your personal data will be collected and used by us, and we may disclose your personal data to third parties where necessary, for a number of business purposes, including:

    • (a)
      Recruitment, including reference checks and verifying the identity and accuracy of personal details and other information provided, for assessing and evaluating suitability of employment in any current or prospective position;
    • (b)
      Schedule work activities and projects undertaken by NEC APAC’s business units and teams;
    • (c)
      Employee performance management and professional development;
    • (d)
      Performing obligations under or in connection with your contract of employment with us;
    • (e)
      All administrative and human resources related matters within our organisation, including:
      • (i)
        Administering payroll, claims reimbursements, accounting or tax purposes;
      • (ii)
        Granting access to our premises and computer systems;
      • (iii)
        Processing leave applications and consumption of employment benefits;
      • (iv)
        Applying for work permits at the Ministry of Manpower, if needed;
      • (v)
        Facilitating corporate insurance coverage and other benefits;
      • (vi)
        Investigating any acts or defaults (or suspected acts or defaults);
      • (vii)
        Developing human resource policies;
      • (viii)
        Administer business travel (i.e., booking airfare, hotels and applying for visa etc.) and other corporate events;
    • (f)
      Knowledge management and training for staff;
    • (g)
      Government and other regulatory reporting;
    • (h)
      Business and market development;
    • (i)
      Publicity, external and internal marketing purposes;
    • (j)
      For security and access controls, safety surveillance and monitoring and reporting purposes, including in emergency situations and for contract tracing purposes;
    • (k)
      For internal reporting and/or accounting or audit purposes;
    • (l)
      Registrations and submissions with relevant governmental or regulatory authorities, and financial institutions (e.g., bank signatories), as necessary;
    • (m)
      Managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
    • (n)
      Ensuring business continuity for us in the event that your employment with us is or will be terminated;
    • (o)
      Assessing and evaluating your suitability for (continued) employment/appointment or redeployment in any position within our organisation or to any member of our group, as set out under clause 6 below;
    • (p)
      Facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
    • (q)
      Facilitating our compliance with laws, customs and regulations applicable to us.
  • 5.

    The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

  • 6.

    We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).


  • 7.

    The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. If you are a job applicant, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

  • 8.

    Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within 30 days of receiving it.

  • 9.

    Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.

  • 10.

    Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.


  • 11.

    If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

  • 12.

    Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

  • 13.

    We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

  • 14.

    Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.


  • 15.

    To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures to secure all storage and transmission of personal data by us.

  • 16.

    You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.


  • 17.

    We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.


  • 18.

    We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

  • 19.

    We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.


  • 20.

    If we transfer your personal data to countries outside of Singapore for further processing, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.


  • 21.

    You may contact our Data Protection Officer at necdpo@nec.com.sg if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request.


  • 22.

    This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

  • 23.

    We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued employment and/or participation in our recruitment process constitute your acknowledgement and acceptance of such changes