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Privacy Policy and Personal Information Collection Statement (“Statement”) 

1. Personal Data (Privacy) Ordinance

Charlotte Frank Limited (the “Company”, “we”, or “us”) is committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the Personal Data (Privacy) Ordinance (the “Ordinance”).  You may wish to visit the official website of the Office of the Privacy Commissioner for Personal Data for more information about the Ordinance.

Where you provide us with your personal data in person, by email, through our Website or through any other means, we will endeavour to ensure that such data remains private and is only used in accordance with this Statement.  By providing us with your personal data, you also consent for us to collect, hold, use and disclose your personal data in accordance with this Statement.

2. Your personal data

It is our policy to protect the privacy of those we deal with and collect data from, including users of our Website. We may, however, collect your personal data from you (by “personal data”, we mean information about you or which can be used to ascertain your identity) including, without limitation, your name, identity card number, contact details, qualifications, work history, your right to work in a particular country, languages spoken, professional memberships and accreditations and other data from your CV.

3. Collection and use of your personal data

Any personal data collected from you, whether through our Website or otherwise, will only be used for the purposes mentioned at the time of collection or for purposes related to those specific purposes and/or in this Statement. 

We hold, use and disclose your personal data for the following purposes:

a. to provide our recruitment consultancy services to you;

b. to maintain our business relationship, where you are a user of our Website, a client or candidate;

c. to enable you to submit your CV generally, to apply for specific jobs or to subscribe to our job alerts;

d. to match your details with job vacancies, to assist us in finding a position that is most suitable for you and, where you have provided your prior consent as a candidate, to send your personal data to clients in order to apply for jobs;

e. to answer your enquiries;

f. to direct-market our products and services, advise you of news and industry updates, events, promotions and competitions, reports and other information.  Where we do so, you will be able to unsubscribe from such communications;

g. where you are registered as a candidate on our database, your personal data may be accessed by our other offices internationally;

h. to different parts of our group internationally to enable the development and marketing of other products and services and to improve our customer service and to make our services more valuable to you, including (without limitation) tailoring our Website when you log on to make it more relevant to you personally;

h. to trusted third parties where we have retained them to provide services that you have requested, such as psychometric evaluations or skills tests, and who also provide services to us, such as professional advisers, IT consultants and mailing houses.  These third parties must comply with similar undertakings of privacy and confidentiality as us;

i. to regulatory or law enforcement authorities, if required by law; and

j. any other purpose not listed above and for which we have sought your consent to collect, hold use and disclose your personal data.

4. Information automatically logged

When you visit our Website we will record your visit only as a “hit”.  The webserver makes a record of your visit that includes your IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited, and time/durations and the pages visited (“visitor data”). We use the visitor data for the purpose of maintaining and improving our Website such as to determine the optimal screen resolution, which pages have been most frequently visited etc. We use such data only for website enhancement and optimisation purposes. We do not use, and have no intention to use the visitor data to personally identify anyone.

5. Cookies

We may use cookies in our Website.  Cookies are small pieces of information that we store on your computer’s or mobile device’s browser or hard drive.  The information stored is to enable the site to function correctly and give you additional features and benefits such as automatic log in.   Most browsers give you the option of preventing cookies from being stored, though doing so may cause you to lose some of the benefits of our Website.  The information collected by means of cookies on our Website about you will be used only for compiling aggregate statistics on how visitors browse our Website. Such statistics are collected for the purpose of managing and improving the design of our Website.

6. Direct marketing

We may use your name and contact details to provide you with information and marketing materials about our recruitment consultancy services and/or related products, but we must obtain your consent (or an indication of no objection) before we can do so.  Please indicate by ticking the box below that you do not object to the use of your personal data in direct marketing above:

  • I do not object to the proposed use of my personal data in direct marketing

​7. Disclosure of information to third party

Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent.  However, your personal data will be used (and disclosed) to third parties, such as potential employers, for the purposes for which your personal data were collected.  Your personal data may also be disclosed where we are required to do so by law.   You should note that data security measures as set out herein does not apply to personal data which is passed to third parties, and we are not responsible for the protection of your personal data or lack thereof by such third parties.

8. Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect.  Practical steps will be taken to ensure that personal data will not be kept longer than necessary or legally permitted.

9. Your right of access to and to correct personal data 

You are entitled, in accordance with the Ordinance, to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to our Privacy/Data Protection Officer Louisa Tang whose email address is lt@charlottefrank.com and who can be contacted on +852 25268588.  

In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.

10. Complaints

If you have any complaint(s) arising from the collection, use and/or disclosure of your personal data, please be informed that your complaint(s) can be sent to the Privacy/Data Protection Officer at the email address stated above.

11. Withdrawal of Consent

Should you wish to withdraw your consent for any of the purposes stated, you may do so by sending us a notice (“Withdrawal Notice”) to the Privacy/Data Protection Officer at the email address stated above, stating the following information:

  • Your name and identification number; and
  • The purpose(s) that you had previously consented to for which you wish to now withdraw your consent for

12. Transfer of Personal Data

As outlined in clauses 3g and 3h it may be necessary to transfer your personal data to our clients internationally or to another entity in the Elliott Scott Group of Companies. The personal data will only be transferred for the purposes stated within clause 3.

13. Internal Policies and Practices

Please be informed that we have developed and implemented policies and practices to comply with the provisions of the Ordinance. Upon your request, we will make available to you information on the policies and practices developed and implemented by us as regards the collection, use and disclosure of personal data about you.

14. Changes to this Statement

We may amend this Statement from time to time.  We suggest that you visit our Website regularly to keep up to date with any changes.

Please be informed that our Charlotte Frank business in Singapore has also developed and implemented policies and practices to comply with the provisions of the Personal Data Protection Act 2012 (Act 26 of 2012) (the “PDPA”). Charlotte Frank is a Branding Division of Elliott Scott HR Recruitment Pte. Ltd with EA License Number: 14C6917

Copyright © 2016, Charlotte Frank Limited. All rights reserved.


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