PRIVACY POLICY
Citadel Search Pte Ltd (“Citadel Search”) is a leading Executive Search Firm and is committed to respecting and safeguarding your privacy. We maintain this Privacy Policy to articulate our commitment to your privacy which sets out the basis upon which Citadel Search (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA
“Personal data” means data, whether true or not, who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Personal data of Candidates which we may collect includes, without limitation, your:

name or alias, gender, full NRIC/FIN (as required by Ministry of Manpower) or passport number, date of birth, nationality, and country and city of birth;
mailing address, telephone numbers, email address and other contact details; resume, educational qualifications, professional qualifications and certifications and employment references; employment and training history;
salary information and bank account details;
work-related health issues and disabilities;
photographs online obtained through private subscription platforms or public access information gathered through professional networking sites;
demographic data as a result of a poll/questionnaire/survey, assessment, enquiry, comments made
online/offline interaction data we have had with you
Privacy Policy: Personal Data Collection
If you are a client/potential client, we may collect your name, title, contact details, comments, requests of our service, or other information that you provide us for the purpose of business interaction and/or for the fulfilment of service delivery and business transaction.

Indirect data may also be collected. Our website uses Cookies, Tags and other tracking technologies (collectively called “Cookies”), which are stored on your device or browser. We use such Analytical or Function Cookies only to optimise your user experience and gather information about your usage patterns and how you navigate our website, in order to analyse new visitors, or otherwise so as to improve the effectiveness of our website.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application, or via a third party who has been duly authorised by you to disclose your personal data to us (and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorised by law).

Privacy Policy: Data Collection
Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to our clients ( HR, Hiring Managers, Senior Management Team members ) third parties including partners whom we work with, vendors, government agencies/authorities where necessary, for the following purposes:

assessing and evaluating your suitability for employment in any current or prospective position;
performing obligations under or in connection with your contract of employment with us or for our clients, including payment of remuneration and tax;
all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organization or for our clients; and
facilitating our compliance with any laws, customs and regulations which may be applicable to us.
By submitting your CV/resume/contact details to us or through any third-party job boards, you have thereby granted us permission to contact you for the purpose of providing you with career opportunities. We explicitly state that we are not under obligation to present you to our clients. We reserve the right to consider your candidature and will take appropriate measures to safe-keep your data.

You may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to the above purposes.

We may use Personal Information to respond to your inquiries and answer your questions about our Services.

We may use your Personal Information in order provide send you career opportunities/ positions that may be of interest to you, and share thought leadership that may be of interest to you.

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Citadel Search or regulatory authorities for regulatory requirements. In relying on the legitimate interests exception of the PDPA, Citadel Search will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

Fraud detection and prevention
Regulatory Compliance and Reporting
Privacy Policy: Fraud Detection
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

WITHDRAWING CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. As a job applicant, you may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within ten (10) days of receiving it.

withdraw consent to our privacy policy
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 30 below.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record if the record of your personal data forms a negligible part of the document.

Privacy Policy: Correction of personal data

PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.

We have security measures in place designed to protect our user database and access to this database is restricted internally.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Privacy Policy: Data Protection

ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

CHANGES TO OUR PRIVACY POLICY
Citadel Search reserves the right to change or amend the Privacy Policy from time to time in its sole discretion as permitted by applicable law. Any changes will be effective when we publish on the website.

Your continued relationship with us constitutes your acknowledgement and acceptance of such changes, unless explicitly indicated to us that you no longer wish to do so, then you can at anytime write to us at the email indicated below.

PERSONAL DATA
“Personal data” means data, whether true or not, who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Personal data of Candidates which we may collect includes, without limitation, your:

name or alias, gender, full NRIC/FIN (as required by Ministry of Manpower) or passport number, date of birth, nationality, and country and city of birth;
mailing address, telephone numbers, email address and other contact details; resume, educational qualifications, professional qualifications and certifications and employment references; employment and training history;
salary information and bank account details;
work-related health issues and disabilities;
photographs online obtained through private subscription platforms or public access information gathered through professional networking sites;
demographic data as a result of a poll/questionnaire/survey, assessment, enquiry, comments made
online/offline interaction data we have had with you
Privacy Policy: Personal Data Collection
If you are a client/potential client, we may collect your name, title, contact details, comments, requests of our service, or other information that you provide us for the purpose of business interaction and/or for the fulfilment of service delivery and business transaction.

Indirect data may also be collected. Our website uses Cookies, Tags and other tracking technologies (collectively called “Cookies”), which are stored on your device or browser. We use such Analytical or Function Cookies only to optimise your user experience and gather information about your usage patterns and how you navigate our website, in order to analyse new visitors, or otherwise so as to improve the effectiveness of our website.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application, or via a third party who has been duly authorised by you to disclose your personal data to us (and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorised by law).

Privacy Policy: Data Collection
Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to our clients ( HR, Hiring Managers, Senior Management Team members ) third parties including partners whom we work with, vendors, government agencies/authorities where necessary, for the following purposes:

assessing and evaluating your suitability for employment in any current or prospective position;
performing obligations under or in connection with your contract of employment with us or for our clients, including payment of remuneration and tax;
all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organization or for our clients; and
facilitating our compliance with any laws, customs and regulations which may be applicable to us.
By submitting your CV/resume/contact details to us or through any third-party job boards, you have thereby granted us permission to contact you for the purpose of providing you with career opportunities. We explicitly state that we are not under obligation to present you to our clients. We reserve the right to consider your candidature and will take appropriate measures to safe-keep your data.

You may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to the above purposes.

We may use Personal Information to respond to your inquiries and answer your questions about our Services.

We may use your Personal Information in order provide send you career opportunities/ positions that may be of interest to you, and share thought leadership that may be of interest to you.

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Citadel Search or regulatory authorities for regulatory requirements. In relying on the legitimate interests exception of the PDPA, Citadel Search will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

Fraud detection and prevention
Regulatory Compliance and Reporting
Privacy Policy: Fraud Detection
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

WITHDRAWING CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. As a job applicant, you may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within ten (10) days of receiving it.

withdraw consent to our privacy policy
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 30 below.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record if the record of your personal data forms a negligible part of the document.

Privacy Policy: Correction of personal data

PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.

We have security measures in place designed to protect our user database and access to this database is restricted internally.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Privacy Policy: Data Protection

ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

CHANGES TO OUR PRIVACY POLICY
Citadel Search reserves the right to change or amend the Privacy Policy from time to time in its sole discretion as permitted by applicable law. Any changes will be effective when we publish on the website.

Your continued relationship with us constitutes your acknowledgement and acceptance of such changes, unless explicitly indicated to us that you no longer wish to do so, then you can at anytime write to us at the email indicated below.

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, terminate the relationship, etc. in the following manner:

Contact No.: 62222687
Email Address : consult@citadelsearch.com.sg
Address: 50 Raffles Place, Singapore Land Tower, Level 19, Singapore 048623

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