At Upper Spring Consulting Pte Ltd, we value your privacy. As part of our compliance with the Personal Data Protection Act 2012, this policy delineates the information on how we collect your personal data and how we maintain, use, store and disclose your personal information and it applies to all individuals (including but not limited to employees, clients, job applicants, and visitors to our website) as well as to all our business operations anywhere in the world.

Consent

By accessing our website, requesting our services, applying for a job with us and/or submitting your personal data to us through any means, you consent to your personal data being collected, disclosed, used, stored or otherwise handled as set out in this policy.

Information Collection Avenues

We may collect personal information about you when:

** You send a message via online forms or provide any other information in connection with your application via email
** You submitted your resume via job portals
** We receive any reference about you
** We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
** We receive the results of any competency or medical test or background checks
** We receive any complaint or other information from or about you in the workplace
** We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved
** You provide us with any additional information about you

Personal Data We Collect

Depending on the type of services you request and any applicable contractual, legislative, filing and/or reporting obligations, we may collect information such as (but not limited to):

** Name
** Contact details
** NRIC / FIN number for statutory submission to Ministry of Manpower (MOM)
** Skills and abilities
** Qualification
** Accreditation
** Employment history
** Aptitude, psychological and/or psychometric assessment results
** Opinions from referees
** Opinions of others about your work performance
** Information about incidences in the workplace

Usage Of Personal Data

We collect some of these information so that we are able to:

** Provide our services to our clients and candidates
** Manage your requests, inquiries, or complaints
** Provide our assessment for our client for the positions we are seeking to fill on their behalf
** Maintain and promote our business or employer-employee relationships
** Inform you of possible work opportunities, relevant candidates, and/or (with your consent) events, products and services that are of relevance to you
** Pay you (should you be engaged as an employee or contractor)

If you do not give us the data we seek we may be limited in our ability to locate suitable work for you

Management Of Personal Data

At Upper Spring Consulting we take a serious approach on the confidentiality of customer data and the privacy of individuals. We have appointed a Privacy Officer to ensure that our management of personal data is in accordance with this policy and the Personal Data Protection Act.

How Do We Store And Protect Personal Data? 

Safeguarding the privacy of your data is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium. We will take all reasonable steps to ensure that the personal data we hold and disclose is accurate, up-to-date, and complete. As such, we may contact you from time to time to check that your personal data is still correct. Please advise our consultant when your personal details changed. We hold personal data in a combination of secure computer storage facilities and paper-based files and other records and take such steps as are reasonable in the circumstances to protect the personal data we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider data is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

Inquiries & Complaints

You can make inquiries, requests to access/delete or correct your data, or complain about alleged breaches of the Personal Data Protection Act 2012 to our Privacy Officer:

Data Protection Officer

privacy@upper-spring.com

Complaints

We aim to acknowledge receipt of all complaints within 10 working days, and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time. If you are not satisfied with our response to your complaint, you can contact the Personal Data Protection Commission.

Access

Subject to some exceptions you can gain access to the personal data that we hold about you.

To make a request to access your personal data, you will need to complete an application form verifying your identity and specifying what data you require. Please contact our Privacy Officer for an application form. We will respond to your request within 30 days after the request is made and provide access to the data in the manner requested. If we are unable to comply with your data access request within 30 days after receiving your request, we shall within that time inform you in writing of the time by which we will respond to your request.

We may impose a moderate charge in providing access. Our Privacy Officer will discuss this with you. You should also anticipate that it may take time to process your application for access as there may be a need to retrieve data from storage and review it in order to determine what data is relevant.

Correction

Subject to some exceptions you may request that we correct the personal data that we hold about you if you deem it to be inaccurate, incomplete, out-of-date, irrelevant or misleading. We will take reasonable steps under the circumstances to correct the data as soon as practicable and send the corrected personal data to other organisations in accordance with the Personal Data Protection Act 2012.

If we refuse to correct your personal data as we are satisfied on reasonable grounds that a correction should not be made, we will notify you in writing of the reasons detailing our refusal to correct the data and the process for escalation regarding this refusal. Should we refuse your data correction request, we shall annotate your personal data with the correction that was requested but not made. If you wish to exercise your rights of correction you should contact our Privacy Officer for an application form or otherwise comply with the applicable statutory requirements. We will not charge you for making the request to correct your data or annotating your personal data with the correction that was requested but not made.

Feedback

You can submit your feedback via Upper Spring website, under the ‘contact us’ section. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or to contact you for further feedback on the site.