Under the revised Employment Agencies Licence Condition 5(b), employment agencies (EAs) are required to collect the personal data (e.g. NRIC, FIN, Passport number ) of all applicants referred to employers for permanent or contract job positions.

PDPA requirements on collection, use and disclosure of personal data are not applicable to EAs that are collecting such information, as it is a regulatory requirement. However, please be assured that such personal data will not be shared with any other parties.

Privacy Policy

This Privacy Policy (“Policy”) sets out the basis which Sol Invictus Advisory Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our candidate or job applicant 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.

1. General

Singapore has enacted the Personal Data Protection Act 2012 (“PDPA”) with effect from 2 July 2014 which strives to protect personal data of individuals. It is our policy to comply with the requirements of the PDPA. In doing so, we will ensure compliance by our staff to the standards of security and confidentiality in line with industry standards. This Singapore Data Protection Notice (“Notice) explains our practices.

Your privacy is of utmost importance to us. This policy outlines how we collect, use, store and disclose your personal data in accordance with the PDPA. Please take a moment to read this Notice so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.

By using our services, you agree and consent to Sol Invictus Advisory Pte. Ltd. (“the Company”, “we”, “our” or “us”) and affiliates as well as our authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your personal data in the manner set forth in this Notice.

We may from time to time update this Notice to ensure that this Notice is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Notice shall apply.

For the avoidance of doubt, this Notice forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

2. What is Personal Data?

Personal data refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access.

Depending on your relationship with us (e.g. prospective or current client, candidate, job applicant or business partner), the personal data about you that we may collect, use, store and disclose include:

a) name or alias, gender, date of birth, nationality, and country and city of birth;

b) mailing address, telephone numbers, email address and other contact details;

c) resume, educational qualifications, professional qualifications and certifications and employment references;

d) employment and training history;

e) work-related health issues and disabilities;

f) photographs; and

g) any additional information provided to us by you

3. Purposes for Collection, Use and Disclosure of Your Personal Data

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, 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 which has not been notified to you (except where permitted or authorised by law). If you are unable to provide your consent, we will not be able to serve you and you will not be able to access our career portal.

If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will adequately seek your consent.

4.How We May Collect Your Personal Data

Generally, we may collect your personal data ourselves or through third parties in ways including the following:

a) during our preliminary discussions with you to establish a new client relationship, enter into employment or for any other business relationship;

b) when you interact with our employees, in particular with your Recruitment Manager;

c) when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us;

d) when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;

e) when you access our website;

f) when you respond to our requests for additional personal data; or

g) when you submit your personal data to us for any other reason.

When you access our website you generally do so anonymously. Your activity may however be monitored by Cookies or other navigational data. “Cookies” are small data files sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

5. We Keep Your Personal Data Confidential and Secure

At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and/or procedural safeguards to protect your personal data against loss, misuse, damage and unauthorized access, modifications or disclosures.

6. Who We May Disclose/Transfer Your Personal Data To

Where your consent is given, the personal data which you have provided to us may be transferred to the parties set out below within or outside Singapore, as may be necessary for any of the Purposes stated above:-

a) our group companies including any of their subsidiaries, parent companies, affiliates, associated entities and any of their branches and offices which may also include entities and activities overseas;

b) banks, financial institutions, credit card companies and their respective service providers;

c) companies providing services relating to employment or management services;

d) agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival;

e) our professional advisers such as our auditors and lawyers;

f) government authorities, regulatory bodies and/or other law enforcement agencies; and

g) courts, tribunals and/or parties to the legal proceedings.

When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted.

If your personal data has to be transferred overseas, we will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.

7. How Long We Keep Your Personal Data For

The PDPA does not prescribe the retention period. However, we shall retain your personal data for as long as necessary to fulfil the Purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required.

8. Contact Us

You can contact our Data Protection Officer (“DPO”) via email: contactus@solinvictus.com.sg

if you have any of the following enquiries:-

A. Access to and Correction of Personal Data

You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested.

To update your personal data in our possession or under our control, please submit a written request to our DPO via email: contactus@solinvictus.com.sg. Our DPO shall strive to respond to you within 30 days of your submission.

Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

B. Withdrawal of Consent

If you wish to withdraw your consent to our collection, use or disclosure of your personal data, please submit a written request to our DPO via email : contactus@solinvictus.com.sg. Our DPO shall strive to respond to you within 30 days of your submission.

Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

9. General Queries

If you have general queries about this policy, our data protection process and/or practices, please submit a written request to our DPO via email: contactus@solinvictus.com.sg on what you would like to enquire on. Our DPO shall strive to respond to you within 30 days of your submission.

The Company reserves the right to change this statement and/or any part thereof.