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Privacy Policy 2000x500

privacy policy

This Privacy Policy (“the Policy”) explains how we process personal data within our worldwide businesses delivering search, consulting and assessment services, including how it affects our website: www.profileasia.com

This Policy was last updated in April 2022. Please review this policy periodically for any changes.

1. INTRODUCTION

Who We Are

This Policy is undertaken by and is applicable to the below legal entities (collectively referred to as “Profile”, “we”, “us”) in the named jurisdictions (“Operative Jurisdiction” in the singular, “Operative Jurisdictions” in the collective):

Registered Legal Entity Name / 
Business Name

Operative Jurisdiction

The Profile Group (Hong Kong) Ltd, doing business as “Profile Search & Selection”

Hong Kong

Profile Search & Selection (Singapore) Pte Ltd

Singapore

The Profile Group (Shanghai) Ltd 

China

WilsonHCG Talent Japan K.K. 

Japan

Profile are committed to protecting the privacy of our Candidates, Clients and users of our websites and other services. We will ensure that the information 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), is only used for the purposes set out in this Policy.    

We are committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the relevant privacy and data protection laws applicable in the Operative Jurisdictions currently in force as below:

Operative Jurisdiction

Applicable Legislation

Hong Kong

Personal Data (Privacy) Ordinance (Cap.486) (“PDPO”) and the 2021 Amendment Ordinance 

Singapore

Personal Data Protection Act of 2012 (“PDPA”), including but not limited to the Personal Data Protection (Amendment) Bill

China

  • Personal Information Protection Law (“PIPL”);

  • Cybersecurity Law (“CSL”); and 

  • Data Security Law (“DSL”)

Japan

Act on the Protection of Personal Information (“APPI”).

Definitions

For the purposes of this Policy:

(a) “Services” refers to the business offerings that we render to a range of Clients throughout the world, including but not limited to executive search, market intelligence, executive assessment and the provision of interim managers. Our complete range of Services may be found here: https://www.profileasia.com/services

(b) “Candidate(s)” means an individual who is a candidate, applicant, potential Candidate, employee of a Client;

(c) “Client(s)” means any business, firm, organisation, government body or individual that mandates us to perform any of our Services;

(d)  “Referee(s)” means any person(s) who provides a personal or work reference in respect of a Candidate and;

(e) “Source(s)” means any person(s) who provides us with information or intelligence about a Candidate.  

Who This Policy Applies To

Client

This Policy applies to you if you are any of the below described persons:-

(a) You are a Candidate for one of our Clients, or an individual we are assessing as an employee of one of our Clients, 

(b) You are a current employee and / or representative of a Client engaging our Services,  

(c) You are a Source or a Referee in respect of a Candidate,

(d) You have attended one of our events or have subscribed to receive information about our Services or any of our marketing materials.

Gathering Information

Our Clients expect that we identify the best individuals to fill roles within their organisations. Therefore, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our Clients, these will include Referees and Sources to help inform our decision-making process. 

The nature of our work means we are required to process personal information quickly, confidentially and often without reference to the data subject. As a result, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest and / or HR management activities where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this Policy.

2. DATA COLLECTION  

How We Use Your Personal Information 

Any personal information we collect from you will be used for legitimate business or regulatory purposes including: 

Candidate

(a)  Processing job applications, in partnership with our Clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant Client to proceed with the application. As a result, you may receive further direct correspondence from them;

(b)  Retaining your details to notify you about future job opportunities other than the specific role for which you have contacted us;

(c)  Searching for relevant Candidates for confidential recruitment assignments where our Client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant Client. If that Client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our Client. At this point, we will pass further details to the Client and you may receive further direct correspondence from them;

(d)  For mapping or research exercises undertaken by us on behalf of our Clients from time to time. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal information. You will not be contacted by any third party about this unless we first obtain your consent;

(e)  For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme;

(f)   For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law; 

(g)  To improve the Services we offer; 

(h)  For marketing purposes to send you information on our Services, industry updates, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us;

(i) (For Candidates presented in respect of Singapore-based Roles only) To satisfy regulatory requirements imposed by the Ministry of Manpower in Singapore. Employment agencies in Singapore are exempt from the usual restrictions around collection, use and disclosure of personal information under the PDPA for this purpose, but are prohibited from sharing such information with their Clients. Please refer to the link here for more information: Are employment agencies allowed to collect personal data such as NRIC or FIN? (mom.gov.sg)We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so. 

Please be aware that we are not responsible for the information processing activities of others, such as our Clients. 

Client

(a)  We will use Client information to perform our Services to you and other legitimate business purposes including but not limited to marketing. 

Source / Referee 

(a)  We will use Source and Referee information to perform our Services, in particular, to enable us to obtain your opinions on a Candidate.

(b)  We may also use this information to enable us to market our Services to you as a potential Client. 

(c)  We may invite you to become a Candidate in respect of the provision of our Services.  

The Type of Personal Information  We Collect and Process

In all cases, we collect and process personal information about you, including your name, address, telephone number and email address. 

Candidate

If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal information. For example, date of birth, education and career history and curriculum vitae (“CV”), or resume. Your CV may contain employment history, education, professional qualifications, memberships, details of papers written, references and Referees, amongst other things. We will likely obtain further personal information about you during the course of our relationship with you.   

We may also collect personal information from third-party databases and other public sources. In addition, we may receive your details and CV electronically through an application that you have made through a third party. 

When required, we will process any relevant psychometric assessments, psychological tests, or results from such assessments or tests. This will be based on your explicit consent.

From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.

Client

As well as basic contact information we will also collect information about your role and other information provided to us by your organisation. 

Source

Along with basic contact information, we will also collect information regarding your credentials as a Source, details of your relationship/knowledge of a Candidate and your opinions of that individual.  We may obtain this information directly from you or publicly available information.  

Who We Share Data With

To help us run this website, and to provide executive search services or assessment services, we work closely with trusted partners with whom we need to share personal information. These partners include:

(a) Our Clients, for whom we provide executive search services;

(b) Our Clients, for whom we provide assessment and coaching of their employees in certain countries; 

(c) Prospective Clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it. 

We will share information only as anticipated within this Privacy Policy and, wherever appropriate, limit disclosure to information in aggregated form, to avoid or limit identifying you personally. 

Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.  

Third Parties

We may also provide information to third-party service suppliers who process the information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.

Your information may also be shared with organisations located elsewhere in the world.  As their privacy laws may not match your home country’s standards, we will only make a transfer of data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.

Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country. 

If you are a resident or data subject of:

  • Hong Kong: We will take all practicable steps to ensure that you are explicitly informed, on or before the collection of your personal information, of the classes of potential transferees, in addition of obtaining your separate and voluntary written consent. 

  • Singapore: We will request your consent to transfer such personal information;

  • China: We will inform you of the name and contact information of the overseas recipient. We will also inform you of the purpose and method of the processing of your personal information, and the type of personal information involved, as well as the way for you exercise your rights provided for by the PIPL against the overseas recipient. Before your personal information is shared with an overseas recipient, we will request your consent to do so. We will not provide any of your personal information stored within the territory of China to a foreign judicial or law enforcement body, unless approved by the relevant PRC authorities.

  • Japan: We will request your consent before sending your personal information to a third party located outside Japan.

We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.

If you are concerned about these arrangements to disclose or share personal information with third parties, you should contact us and ask us not to process your personal information.

Keeping Your Records

We store your personal information on our database, which is accessible by Profile staff only.  We keep your information for as long as required to provide our Services, and in accordance with legal, tax and accounting requirements. As we often support Candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain Candidate information is often ongoing.  We conduct regular data-cleansing and updating exercises with our Candidates to ensure that (a) the information that we hold is accurate and (b) we are not holding information for too long. 

Where your personal information is no longer required, we will ensure it is disposed of in a secure manner.

Where required by law, we will notify you when this has happened.  

Sensitive Information 

From time to time, we will seek your consent to process personal information in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal information: racial or ethnic origin, creed, social status, religious or philosophical beliefs, financial account information, tracking/location information; minors data, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.   

3. RIGHTS

(a) You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our Services. 

(b) For residents or data subjects in Singapore, you have the following rights:

·      Request access to your personal information;

·      Request correction of your personal information;

·      Right to withdraw your consent at any time by giving reasonable notice. 

(c) For residents or data subjects in Hong Kong, you have the following rights:

·      Request access to your personal information;

·      Request correction of your personal information;

·      Right to object to direct marketing and profiling;

·      Right to be forgotten. 

(d) For residents or data subjects of the People’s Republic of China, you have the following rights:

·      Right to know and make decisions;

·      Right to access and make copies;

·      Right to transfer; 

·      Right to correct and complete;

·      Right to delete;

·      Right to request explanation;

·      Right to withdraw your consent

(e) For residents or data subjects in Japan, you have the following rights:

·      Right to disclosure;

·      Right to correction, addition or deletion;

·      Right to cessation of use or deletion;

·      Right to cessation of provision to third parties, regarding retained personal data.

(f) To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.

(g) In certain circumstances, in countries where it is required or permitted by law, we might not be able to provide you with access to some of your personal information. Wherever possible, we will notify you of the reasons for this.   

4. GENERAL INFORMATION 

Local Agreements

In certain countries, we will not collect personal information from you unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels, or via other similar measures required by local privacy and data protection laws.

We may also provide services to our Clients in certain countries that entail the assessment and coaching of their employees. Here, depending on the specific assignment, we will either process your personal data to meet the legitimate interests and/or HR management activities pursued by the Client or act on their behalf, in accordance with their instructions. If our Services include any psychometric assessments or psychological tests, and we’re not acting on behalf of your employer, we will obtain your specific consent.

In some locations, we provide services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our Services include any psychometric assessments or psychological tests, we will obtain your specific consent.

Newsletters and Other Communications

If you would like to receive one of our newsletters, we will ask you to provide us with your name, email address, job title, company name and country of residence.  

When you have indicated you would like to receive newsletter(s) from us, we may send email alerts and bulletins about our Services and any roles that might interest you.

You can unsubscribe from our electronic marketing messages by following the “unsubscribe” instructions included in our communications. Also, you may change your preferences and cease receiving direct marketing from us through your email account settings.

From time to time, we may contact you with updates on our Services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.

Information about Others

If you provide us with information about other individuals, like details of a Referee or personal contact, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of or link to, this Privacy Policy. ​

About Our Website

This Privacy Policy applies to our website too, where we process personal data within and through this website: www.profileasia.comThe primary purpose of our website is to provide you with information regarding the services provided by Profile group of companies and consultants. 

We might also use your data, to help our Clients understand who is making use of our website and how their job vacancies are being viewed.

Analytics

We use analytics tools and cookies on this website to help deliver our online services, identify any service issues, improve our Services, provide content tailored to users' personal preferences, and to monitor site traffic and usage.

These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal information, to certain third-party services providers in order to obtain such services.

Cookies

Cookies are small computer files which are downloaded onto your device when you browse the web. They collect information about the way in which you navigate and use this website and the wider web. This information may allow us to identify you or your approximate location. Cookies also help us provide you with a more personal experience, like a local version of the website in a local language. Information from cookies also allows us to make improvements to our Services.

We only collect "session" cookies, which are not usually stored after your browsing session has ended. These are used to establish your approximate location and to serve up the website in an appropriate language.

You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.

Keeping Information Secure

We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.   

Third Party Websites

This Policy only applies to this website. If you land on our site from other websites or move to other ones from our website, you should read their separate privacy policies.

Complaints Procedure

If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal information   

Contacting Us

If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal information, please contact us at support@profileasia.com or write to: 

Profile Search & Selection
​16/F, 8 Wyndham Street,
​Central, Hong Kong