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Asia Pacific Recruitment Privacy Notice
Privacy Policy APAC

Asia Pacific Recruitment Privacy Notice

Updated July 2020

This is the ‘Recruitment Privacy Notice’ of SYKES’ companies in Asia Pacific (“Sykes”; “We”). This notice applies to individuals applying to work with us in the Philippines, Australia, India and China, including prospective employees, workers and contractors.

We are a data ‘controller’, which means we are responsible for deciding how we hold and use your Personal Information. This Notice explains how and why we will collect and use your Personal Information in the context of the recruitment process and your rights in relation to the processing of your Personal Information.

This Notice is also available in Mandarin. In the event of any conflict between the English version and the translation, the English version of this Notice shall prevail.

Your Personal Information

In this privacy notice, your ‘Personal Information’ means your personal data, i.e., information about you from which you can be identified. Your ‘Personal Information’ does not include data where the identity has been removed (anonymous data).

It is important that your Personal Information is accurate and up to date. Please inform us if your Personal Information changes during the recruitment process.

Where does your Personal Information come from?

Your Personal Information will come from you or us, and may also come from the following sources:

  • Recruitment agencies may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • A contact of yours may provide us with the following personal information as part of our employee referral program; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references;
  • Student organizations may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • Job boards/portals may provide us with the following personal information; name, date of birth, contract details (email address, phone number, physical address), career history, educational establishments attended, certifications, references, immigration status;
  • When you apply or reach out to us thru our official social media channels (where allowed by applicable law);
  • In the following countries background check providers may provide us with the following Personal Information criminal records, media articles, address history, credit history, account payment history and any public records: Philippines, China, Australia and India.
  • Former employers, whom you have given us permission to contact, may provide us with the following personal information: job titles, salary, work history, evaluations, disciplinary actions, attendance records.

If you would like more information about the source of your Personal Information, please contact the Human Resources or Recruitment Department in the country where you are applying for a job.

Processing your Personal Information

We may process your Personal Information during and after the recruitment process. This may include collecting your Personal Information, recording it, storing it, using it, updating/amending it, consolidating, destroying it and, in some circumstances, disclosing it.

In general, the Personal Information you provide may be used in connection with any of the following:

  • Assess your employment application for actual or possible work placement within our sites;
  • Retain records relating to the recruitment process;
  • Establish, exercise or defend legal claims;
  • Facilitate any test or assessment (including those medical in nature) that you might be required to undergo in connection with your employment application;
  • Conduct criminal reference checks and other background checks, including credit checks for positions involving significant financial risks and otherwise permitted by law;
  • Retain records relating to the recruitment process;
  • Establish, exercise or defend legal claims;
  • Comply with the law [or requirements of a regulator]; and / or
  • Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

You may be required to provide your consent and accept a Privacy Notice in one of our tools, in jurisdictions where consent is mandatory. Your acceptance and confirmation of the Notice will serve as your consent to the processing of your Personal Information for the stated purposes.

Reason for processing your Personal Information

Reason Legal Grounds Information
  • Contract you regarding the recruitment process and any offer of work
  • To enter a contract
  • Personal contact details (including name, address, email, telephone number)
  • Contact you regarding new positions that we may recruit for in the future
  • For our legitimate interests, to source suitable employees, works and contractors
  • Personal contact details (including name, address, email, telephone number)
  • Your application form, CV and any covering letter or email.
  • Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the work
  • Where applicable, and where the Sykes entity has an eRecruitment Portal, transfer your contact information, education data, CV or resume and other personal information supplied by you in our eRecruitment Portal
  • To enter a contract or to comply with a legal obligation and for our legitimate interests:
    • to select suitable employees, workers and contractors
  • Your application form, CV, any covering letter or email, and interview notes
  • Results of recruitment tests
  • If you have accepted an offer of work from us that is subject to such checks:
  • Take up references (from referees whom you have given us permission to contact);
  • Carry out background checks;
  • Confirm your professional memberships, registrations and / or qualifications.
  • To enter a contract or to comply with a legal obligation
  • For our legitimate interests:
    • to select suitable employees, workers and contractors
  • References and details of previous employers
  • Professional memberships, registrations and qualifications
  • Correspondence and results regarding background checks.
  • Determine the terms of any potential contract between you and us
  • To enter a contract or to comply with a legal obligation
  • Offer letter, and proposed contract between you and us
  • If you have accepted an offer of work, check you are legally entitled to work in the relevant country
  • To enter a contract or to comply with a legal obligation
  • Documentation confirming your right to work in the relevant country
  • Establish whether you can undergo an assessment which forms part of the application process or consider reasonable adjustments to the recruitment process for disabled applicants
  • To enter a contract or to comply with a legal obligation
  • For our legitimate interests:
    • To select suitable employees, workers and contractors
  • For special categories of information:
    • To exercise or perform employment law rights or obligations
  • Information about a disability, the effects of that disability, and special arrangements that may need to be made to the recruitment process as a result of that disability*
  • Establish whether you will be able to carry out a function that is intrinsic to the particular work
  • If you have accepted an offer of work from us that is subject to such a check: assess your fitness to work via a health questionnaire or medical report
  • To enter a contract or to comply with a legal obligation
  • For our legitimate interests:
    • To select suitable employees, workers and contractors
  • For special categories of information:
    • To exercise or perform employment law or obligations
    • For the purposes of preventive or occupational medicine, or for the assessment of your working capacity
  • Health data and sickness records, including disability information
  • Information about criminal convictions

To enable us to make recruitment decision and access suitability for particular work, we may process information about criminal convictions and offences (including alleged offences). We will process this information for our legitimate interests in selecting suitable employees, workers and contractors, and to exercise or perform employment law rights or obligations.

Providing your Personal Information is voluntary. However, if you choose not to provide all of the data that is requested for your application, SYKES’ ability to consider you as a candidate may be limited.

Information Sharing and Disclosure

Your Personal Information will be shared within SYKES Human Resources community and its other business groups to determine how well your application fits the position you have applied for, or possible future postings. Additionally, your application data will be viewed together with additional information you provide during recruitment process (e.g. interviews, assessments, references). Access to your Personal Information will be limited to people in our organisation who need it for the purposes set out in this Notice.

Subject to local requirements or legislation, your Personal Information may also be transferred to other countries where SYKES does business or to its affiliates and parent company for employment consideration and other business purposes, or to its external service providers who support SYKES with the administration of recruitment application and verification. International transfers of Personal Information will take place in accordance with the appropriate international data transfer mechanism and safeguards.

It is your responsibility to obtain consent from references before providing their Personal Information to us.

Statutory requirement to provide your Personal Information

In some circumstances, the provision of your Personal Information is a statutory requirement. This includes:

  • Documentation confirming your right to work in the relevant country – if you don’t provide this, we may not be able to enter into a contract with you.
  • The information regarding criminal convictions, where we have stated in the job advertisement that this is a statutory requirement.
  • Sharing your personal information with third parties.

We may share your Personal Information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

  • Other entities in the SYKES group of companies where the hiring manager is in another country, for system maintenance support and hosting of data;
  • Our service providers, including applicant tracking system providers, background check providers test providers and payroll providers;
  • With our clients for the purposes of validating our selection processes;
  • Health professionals and occupational health providers involved in your care, for the purposes of establishing whether you can undergo an assessment which forms part of the application process; considering reasonable adjustments to the recruitment process for disabled applicants; establishing whether you will be able to carry out a function that is intrinsic to the particular work;
  • Our professional advisors, including lawyers;
  • Other third parties as necessary to comply with the law.

Special Notice Regarding Children

We will not knowingly collect Personal Information from children without insisting that they seek prior parental consent.  If you are underage, please do not provide your Personal Information to us.

Data Retention

If you don’t start working with us following the recruitment process, we will retain your personal information based on the following criteria:

  • Our ongoing relationship with you, in case you are subscribed to our E-Recruitment portal;
  • When required to do so by a legal obligation to which We are subject;
  • to allow us to establish, exercise or defend legal claims; and
  • for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for, or a similar role, becomes available again 

If your application is successful, your Personal Information will be used for personnel administration including the establishment of personnel record and management purposes. Your contact information might be used to improve your job application experience and the SYKES’ HR recruitment process.  We will give you a copy of our Worker Privacy Notice and will retain your personal information as detailed in the Worker Privacy Notice.

Protection of Personal Information

We strive to protect your Personal Information while it is under our control. We maintain appropriate organisational, physical and technical security measures to protect Personal Information consistent with applicable data privacy and security laws. We have internal controls and relevant policies and procedures to maintain these measures taking into account the risks associated with the categories of personal data and processing we undertake.

If applicable, your account information is accessible online through the use of password. To help protect the confidentiality of Personal Information, you must keep your password confidential and secured. You are responsible for all uses, and acts on the Sites by any person using your password. Please contact us immediately if you believe your password has been compromised or misused.

If a data breach involving your Personal Information occurs, or we suspect that a data breach has occurred, whether the entity experiencing the data breach is SYKES or third parties we use, such as contractors or subcontractors, or our clients, we will expeditiously conduct an investigation and assessment.

Access to and Correction of Personal Information

If you have any questions about this Privacy Notice or complaints about how we have dealt with your Personal Information, or if you wish to exercise your data subject rights, including withdrawal of your consent, please contact SYKES Data Protection Officer at dpo.apac@sykes.com.  We encourage and welcome individuals to contact us first to seek resolution of any complaint.

Please note, however, that certain Personal Information may be exempt from such access, correction, deletion requests pursuant to applicable data protection laws and regulations.

Additional information about SYKES’ Personal Data collection and use practices can be found at https://www.sykes.com/privacy-policy.

Policy Updates

This Policy may change from time to time.