Privacy Policy

Objectives

The objectives of this Policy are to:

(a)          Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of personal data.

(b)          Describe the ways in which Headington collects, uses, discloses, and retains personal data.

(c)          Ensure that Headington complies with the PDPA.

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1.           Personal Data

"Personal Data" is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.

Examples of Personal Data Headington collects may include but is not limited to:

your name, address, telephone and online ID, email address, NRIC/Passport number, nationality, bank account details, details of family members, current occupation, connections to Headington, and details of assets.

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2.           Collection of Personal Data

Headington may collect Personal Data in the following ways, including but not limited to:

• when you submit documents or information for an employment application, such as a CV, or when such information is received from employment agencies and references;

• during the course of you engaging our services;

• when you provide information or documents to us;

• from public information sources and third-party sources;

• via information searching services;

• photographs and videos taken by us or our representatives when you attend events hosted by Headington;

• CCTV recordings from Headington premises;

• via information communicated to us over the phone, fax, email, face-to-face meetings, letters, or other modes of contact;

• during events organised by Headington; and

• when you submit Personal Data for any other reason.

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3.           Purposes of Collect, Use, and Disclose Personal Data by Headington

Generally, Headington collects, uses, and discloses Personal Data for the following purposes:

• providing of Headington's services;

• conducting identity checks, payment processing, Headington administrative and business matters (including assessing employment applications and related qualifications);

• providing legal updates and other information relating to Headington;

• evaluating and improving Headington's services;

• compliance with the relevant laws and regulations, guidelines, practice directions, policies, procedural and regulatory requirements (which may extend to know-your-client and related reviews) issued by relevant authorities;

• responding to feedback and queries; and

• any other purpose relating to any of the above.

Headington may from time to time inform you of any other purpose which Headington will use, collect, and disclose your Personal Data if required.

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4.           Headington's Disclosure of Personal Data to Third Parties

Headington will not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so. However, please note that Headington may disclose your Personal Data to third parties without first obtaining your consent in certain situations. For more information on the exceptions, you are encouraged to peruse the Second, Third, and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.

Where Headington discloses your Personal Data to third parties with your consent, we will employ our best efforts to require such third parties to protect your Personal Data.

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5.           Data Protection Officer ("DPO")

For further information about this Policy or to access our complaint handling procedure, please address your correspondence to:

Address:             40 Paya Lebar Road #06-28
Paya Lebar Square, Singapore 405091

Attn:                     Data Protection Officer

Email:                  DPO@Headington.management

(Further details of our policy can also be found in the link here.)

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