PRIVACY POLICY

1. POLICY STATEMENT

1.1   Everyone has rights to know how their Personal Data will be handled. During the course of our activities, we will collect, use and disclose (as reasonably necessary) your personal data in order for us to carry out temporary staffing, permanent placement, career transition and talent development services, as well as, outsourcing and consulting services (“Services”). Achievers prioritizes the need to treat your Personal Data in an appropriate and lawful manner.

 

 

1.2   The types of Personal Data that we may collect for the provision of our Services include details of current, past and prospective candidates, suppliers, customers and other parties that we communicate with. Achievers takes reasonable security measures to ensure the protection of Personal Data which we collect whether on paper, computer or any other form of media.

2. STATUS OF & COMPLIANCE WITH THE POLICY

2.1   This data protection policy (“Policy”) has set out Achievers’s internal regulations and standards on data protection including any legal requirements that must be satisfied in relation to the collection, use and disclosure of Personal Data.

 

 

2.2   The Data Protection Officer of Achievers is responsible for ensuring compliance with this Policy and the applicable data protection laws and regulations. Any questions or concerns about this Policy should be addressed to our Data Protection Officer at: enquiries@achievers.com.hk.

3. DEFINITION OF PERSONAL DATA & PROCESSING

3.1   Personal data means data relating to an individual who can be identified from that data (or from the combination of that data and other information in our possession) (“Personal Data”). Personal Data includes without limitation the following:
  • name
  • address
  • contact details
  • nationality
  • photograph
  • identification card number
  • educational and professional background
  • interests
  • languages

 

 

3.2   Processing” means the carrying out of any operation or set of operations in relation to Personal Data and includes any of the following:

  • recording
  • holding
  • organisation adaptation or alteration
  • retrieval
  • combination
  • transmission
  • erasure or destruction

4. CONSENT OBLIGATION

4.1   All collection, use or disclosure of Personal Data shall be subject to your prior consent.

 

4.2   Achievers seeks consent prior to the collection, use and disclosure of Personal Data. Unless otherwise permitted by the applicable Data Protection Laws, the granting of this consent will be a pre-condition for the collection, use or disclosure of your Personal Data in relation to the provision of the Services. You are entitled to withdraw your consent at any time by giving prior notice to us. Such withdrawal shall apply prospectively and only affect Achievers’s future use or disclosure of your Personal Data.

5. PURPOSE LIMITATION OBLIGATION

5.1   Personal Data may only be processed for the purposes notified to you when the Personal Data was first collected or for any other purposes specifically permitted under the applicable Data Protection Laws. This means that Personal Data will not be collected for one purpose and then used for another purpose. If it becomes necessary to process the Personal Data for a new purpose, Achievers will inform you of the new purpose and seek your consent before processing the Personal Data for any new purpose.

 

5.2   Achievers will only collect Personal Data that is necessary for the performance of the Services.

 

5.3   Achievers will use the collected Personal Data in accordance with the purpose which you have consented to which will include the following (“Purpose”):

  • introducing and recommending you (including sending your resume and Personal Data) to Achievers’s clients, affiliated companies, agents or sub-contractors that are engaged in the same or similar recruitment business as Achievers, for recruitment purposes or recruitment collaborative purposes;
  • sending you directly or via Achievers’s clients, Achievers’s affiliated companies, agents or sub-contractors for reasoning test, psychometric test, personality test, career aptitude test or any tests to determine your skills and suitability for the job(s);
  • discussing with Achievers’s clients regarding your eligibility or suitability for a job application;
  • discussing with your past employer(s), educational institution(s) to establish your employment history, reference checks or educational history;
  • calling you to make arrangements for interviews;
  • sending you internal Achievers’s newsletters periodically;
  • calling you (including leaving voice messages) or short message services (SMS), WhatsApp or sending you text or other communication (text or image) applications for mobile device or via any electronic means (including electronic mailing) and facsimile or send invitations to you on job alerts, recruitment events, etc.
  • meet any legal or regulatory obligations or requests issued by any court, legal or any regulatory bodies (including the agents of the regulatory bodies) to conduct audit checks, surveillance and investigation;
  • meeting or complying with Achievers’s internal policies and procedures;
  • storage and processing of your Personal Data; and
  • any other purposes which are reasonably related to the aforesaid.

6. NOTIFICATION OBLIGATION

6.1Achievers will inform you of the purposes for which your Personal Data will be collected, used and disclosed in order to ensure you are able to provide informed consent.

7. ACCURACY OBLIGATION

7.1   Personal Data needs to be accurate and kept up to date. Personal Data which is incorrect or misleading is not accurate and steps will be taken by Achievers to check the accuracy of any Personal Data at the point of collection and subsequently at regular intervals. Inaccurate or out of date Personal Data will be destroyed.

 

7.2   Achievers will also require your assistance to provide accurate and complete Personal Data at the time of our collection of Personal Data from you. If you wish to correct or update your Personal Data, you may contact our Data Protection Officer.

8. RETENTION LIMITATION OBLIGATION

8.1   Achievers will cease retention of any Personal Data after two (2) years from the date of collection or for as long as required under the relevant Data Protection Law.

9. ACCESS, CORRECTION & DELETION RIGHTS

9.1   You are entitled to request access and to correct or delete the Personal Data collected by Achievers. Such request to correct or delete data will generally be complied with, unless Achievers sees no reasonable reasons for the correction (e.g. the Personal Data is scheduled for deletion).

10. PROTECTION OBLIGATION

10.1   Achievers will put in place procedures to maintain the security of all Personal Data from the point of collection to the point of destruction.

 

10.2   Achievers has implemented administrative and technical measures to protect all Personal Data that we have collected.

Security procedures include, but are not limited to, the following:

  • entry controls;
  • secure lockable desks and cupboards;
  • methods of disposal: paper documents should be shredded; CD-ROMS or disks should be physically destroyed when no longer required;
  • equipment: data users should ensure that individual monitor do not show confidential information to passer-by and that they log off from the PCs when it is left unattended;
  • personal laptops will not connect to the Achievers’s network;
  • firewall, antivirus are in place to filter off incoming network traffic;
  • off-boarding process of all staff, to ensure all access to IT system is revoked and all confidential documents are returned to Achievers; and
  • Personal Data will be destroyed according to legal or industry standard, whichever is stricter.

11. TRANSFER LIMIATION OBLIGATION

11.1   Achievers may also transfer your Personal Data to Achievers’s employees, officers, directors, clients (and its agents), suppliers (mainly, IT providers and financial and legal advisors), authorities (and its agents), and to other Achievers affiliates, based locally or abroad, in order to reasonably achieve the Purpose (as applicable).

 

11.2   Transfers to third parties will be strictly on a need to know basis, in order to comply with contractual or legal obligations and provided that such third parties have data protection standards comparable to Achievers’s.

12. OPENNESS OBLIGATION

12.1   This Policy has been prepared by Achievers to set out our legal obligations in respect of compliance with the applicable Data Protection Laws and Achievers’s internal regulations, as well as, to inform of our commitment to ensure the protection of Personal Data. Further information regarding this Policy or any complaints about any failure to protect the Personal Data in accordance with this Policy can be directed to the Achievers Data Protection Officer.

13. REVIEW OF THE POLICY

13.1   Achievers will continue to review the applicability and effectiveness of this Policy on an annual basis – or more frequently in light of any potential developments – to ensure it is achieving its objectives.

14. MISCELLANEOUS

14.1   This Policy shall be read in conjunction with any local Data Protection Laws. In the event of any conflict or inconsistencies between the provisions of this Policy and those in the local Data Protection Laws, the more restrictive provision for Achievers shall prevail.