PRIVACY NOTICE
SKILLPOWER SERVICES (THAILAND) COMPANY LIMITED
BORDERLESS TALENT SOLUTIONS RECRUITMENT COMPANY LIMITED
HR POWER SOLUTION RECRUITMENT COMPANY LIMITED
MANPOWER PROFESSIONAL AND EXECUTIVE RECRUITMENT COMPANY LIMITED
1. Introduction
SKILLPOWER SERVICES (THAILAND) COMPANY LIMITED, BORDERLESS TALENT SOLUTIONS RECRUITMENT COMPANY LIMITED, HR POWER SOLUTION RECRUITMENT COMPANY LIMITED and MANPOWER PROFESSIONAL AND EXECUTIVE RECRUITMENT COMPANY LIMITED (“Manpower”) has established and disclose this Privacy Notice as its approach to explain how we collect, use or disclose personal information and how we protect personal information and properly handle such information according to the Personal Data Protection Act B.E. 2562 (“PDPA”).
What do we mean by ‘Personal Information’ or ‘Personal Data’?
− Personal Information, also referred to as Personal Data, is information that whether alone, or combined with other information, allows you to be identified directly, or indirectly. Common personal data identifiers are attributes like your name, online identifier, or ID numbers. However, a combination of one or more elements specific to your physical, physiological, genetic, psychological, economic, cultural, or social identity may also be identifiable personal information, given their potential to identify you when combined.
− Some personal data types are considered more sensitive than others and the definition of sensitive data varies by local law. Across several major privacy laws, sensitive data examples include health and financial data, ethnic and racial origins, political opinions, genetic and biometric data, an individual’s sex life or sexual orientation, religious/philosophical beliefs, trade union membership, precise geolocation and government issued identifiers.
This Privacy Notice isfor the following data subjects:
Our customers: General customers, and directors, agents or authorized representatives or persons acting on behalf of juristic person customers
Current vendors, supplier and/or prospective vendors, supplier as well as directors or authorized representatives or persons acting on behalf of juristic person vendors
Job applicants, trainee applicants and their reference persons
Employees, trainees and their family members
Otherswhose personal information collected, used or disclosed by us
In this regard, Manpower does not collect personal information of minors who are under 10 years old. In the case where a minor who is under 10 years old wishes to inquire, use our website or application, use our services, or enter into any agreement with us by which the minor is required to provide his/her personal information to Manpower, the minor’s parents or legal guardian have to take such action on behalf of the minor. In the case where a minor is over 10 years old but has not reached the legal age and cannot take legal actions which the minor has to provide the personal information (e.g. name, address, e-mail) to Manpower, Manpower may ask for consent from the minor’s parents or legal guardian directly or may ask the minor to inform his/her parents or legal guardian to give consent for such action(s) to Manpower.
2. Details of Collection, Use or Disclosure of Personal Information
2.1 Customers
2.1.1 Personal information we collect, use or disclose and sources of information
(1) Personal information we collect, use or disclose
Manpower collects several types of personal information, including:
Identity Data (for example, name, surname, identification card number, passport number, birthdate, gender, age, nationality, marital status, photos,and in some cases we may process sensitive data such as race, religion, fingerprint only with your explicit consent or when permitted by law)
Contact Data (for example, address, telephone number, e-mail, LINE ID, Facebook account)
Financial or transaction data (for example, credit card number, cash card number, income information, transactions related to our products or services)
Communication data (for example, images or voice recordings when communicating with us)
Geolocation data (for example, IP address or GPS Location)
(2)Sources of information
Manpower may collect your personal information from various sources as follows:
(a) Collect information directly from you, for example:
Procedures for applications for using our services, contract signing, form filling, questionnaires, registrations or submission of claims or requestsfor exercising your rights
Your communication with us via our contact channels, e.g. telephone, e-mail, LINE, Facebook Messenger, etc.
Information on participating in activities held by us, e.g. static images or videos
Automatic data storage system, e.g. when you use our website or application, etc.
(b) Collect information from other sources, for example:
Our customers, agents or service providers
Our group companies or our business partners
Government authorities or other publicly available sources such as company website, information made available on the internet or social media platforms, e.g. Facebook, etc.
2.1.2 Purposes of Collection, Use or Disclosure of Personal Information
Manpower collects, uses or discloses your personal information for various purposes depending on relationship between you and Manpower as follows:
Processing purposes |
· To consider applications for using our products or servicesor to enter into an agreement between you or legal entity which you are an authorized representative and Manpower |
· To use products, benefits or services of Manpower, including products, benefits or services of our group companies and our business partners which are jointly launched with Manpower, to perform contractual obligations, to comply with our internal procedures, receipt or delivery of information or documents between you and Manpower including to comply with any regulations of government authorities which are necessary for the performance of contract between you and Manpower |
· To participate in activities of Manpower and our group companies which are operated by Manpower, group companies or third parties (e.g. lucky draw, prize trivia quizzes, trainings, seminars, or field trips, etc.) |
· To assess, improve and develop our products, services and sales promotion |
· To comply with legal obligations and law enforcement requests, and to report or disclose information to government authorities as required by laws |
· To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims |
· To conduct business planning, reporting and forecasting |
· To preventfraud or undertake detection, investigation or other legal actions |
· To monitor security in our building or premises including I.D. card deposit before accessing such areas and using CCTV to collect images of those who contact us at our building or premises |
· To manage risks and undertake internal audit and administration |
· To manage our relationship with you, for example to communicate on any information enquiry, to manage your feedbacks, to offer benefits, and to inform you of any notification without marketing purposes |
· To inform you of any information about products or services, benefits, sales promotion, marketing activities, activity invitation, and to offer products or services of Manpower and our group companies |
· To survey your needs, satisfactions and suggestions about our products and services and spending or service using records, including your interests in order to offer products or services and develop our products and services to meet your needs. |
· To disclose to our agencies, contractors/subcontractors and service providers for any operations of Manpower |
· To disclose to our group companies and business partners in order to improve our services and offer benefits and current products or services of Manpower, our group companies and our business partners including products or services to be jointly launched in the future, and to inform any benefits and sales promotion |
2.1.3 Data Retention Period
Manpower retains your personal information for as long as is considered necessary for the purpose for which it was collected, used or disclosed as set out in this PrivacyNotice.The criteria used to determine our retention periods include: we retain the personal information for the duration we have an ongoing relationship with you and provide the services to you; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be comply with, for any other cause, our internal policies and regulations.
2.1.4 Data Disclosure
Manpower may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Notice to:
(1) Subsidiaries, group companies and any related companies (i.e. (1) a company that holds shares in Manpower and/or a company whose shares are held by Manpower, and/or (2) a company whose shares are held by the company/companies indicated in (1) herein above whether directly or indirectly) for business purposes, internal management, offering for sale of other products and services which you may be interested in, including undertaking any other activity as set out in this Privacy Notice.
(2) Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials.
(3) Agencies, contractors/subcontractors and/or service providers for any operations of Manpower such as
Carriers, providers of card issuing or destruction,document storage and destruction service providers, printing house, marketing agency, research companies, IT development and maintenance companies, travel and accommodation services companies
Auditors, lawyers, tax and legal advisers and any consultants
Call center service providers
Gas station design service providers
(4) Our business partners or other third parties as per your consent or contractual requirements or legal requirements, as the case may be
2.2 Vendors or Suppliers
2.2.1 Personal Information We Collect, Use or Disclose and Sources of Information
(1) Personal information we collect, use or disclose
Manpower collects several types of personal information, including:
Identity Data (for example, name, surname, identification card number, passport number, birthdate, gender, age, nationality, marital status, photos,and in some cases Manpower may process sensitive data such as religion, fingerprint, health information or criminal records only with your consent or when permitted by law)
Contact Data (for example, address, telephone number, e-mail, LINE ID)
Transaction data (for example, bank account number, financial history information)
Communication data (for example, images or voice recordings when communicating with us)
Information on participating in activities held by Manpower (for example, static images or videos)
Information on monitoring work performance under agreement (for example, images or voice recordings during the work performance)
Geolocation data (for example, IP address or GPS Location)
(2) Sources of information
Manpower may collect your personal information from various sources as follows:
(a) Collect information directly from you, for example:
Procedures for applications for using our services or taking steps as per your request before entering into contract, contract signing, form filling, questionnaires, registrations or submission of claims or requests for exercising your rights
Your communication with us via our contact channels, e.g. telephone, e-mail, LINE, etc.
Automatic data storage system, e.g. when you use our website or application, etc.
(b) Collect information from other sources, for example:
Our agents or service providers
Our group companies or our business partners
Government authorities or other publicly available sources, such as company website, information made available on the internet or social media platforms, e.g. Facebook, etc.
2.2.2 Purposes of Collection, Use or Disclosure of Personal Information
Manpower collects, uses or discloses your personal information as a vendor or supplier or a director, agent, authorized representative or person acting on behalf of the individual or the legal entity registering to be a vendor or supplier of Manpower for several purposes depending on relationship between you and Manpower as follows:
Processing purposes |
· To consider your qualifications before entering into an agreement with Manpower |
· To consider and approve entering into an agreementbetween you and Manpower |
· To perform contractual obligations and inspect work performance under the agreement between you and Manpower, to comply with our internal procedures, to receive and deliver documents between you and Manpower, or to provide building/premises entry cards |
· To comply with legal obligations and law enforcement requests, and to report information to government authorities as required by laws |
· To consider your employees or representatives’ qualifications, to inspect your employees or representatives’ work performance, including to monitor security during work performance under the agreement between you and Manpower |
· To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims |
· To conduct business planning, reporting and forecasting |
· To undertake detection, investigation and other legal actions |
· To monitor security in our buildings or premises including I.D. card deposit before accessing such areas, and using CCTV to collect images of those who contact us at our building or premises |
· To manage risks and undertake internal audit and administration |
· To monitor your employees or representatives’ work performance viaCCTV for surveillance and security purposes during work performance under the agreement between Manpower and you |
· To invite you to participate in any activities held by Manpower or third parties including communication on such activities which your images and voice will be recorded during such activities |
· To record in our database for the purpose of vendor or supplier selection and/or for any other project in the future |
2.2.3 Data Retention Period
Manpower retains your personal information for as long as is considered necessary for the purpose for which it was collected, used or disclosed as set out in this Privacy Notice. The criteria used to determine our retention periods include: we retain the personal information for the duration we have an ongoing relationship with you; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be comply with, for any other cause, our internal policies and regulations.
2.2.4 Data Disclosure
Manpower may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Notice, to:
(1) Subsidiaries, group companies and any related companies (i.e. (1) a company that holds shares in Manpower and/or a company whose shares are held by Manpower, and (2) a company whose shares are held by the company/companies indicated in (1) hereinabove whether directly or indirectly) for business purposes, internal management, offering for sale of other products and services which you may be interested in, including undertaking any other activity as set out in this Privacy Notice.
(2) Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials.
(3) Agencies, contractors/sub-contractors and/or service providers for any operations of Manpower such as
Carriers, document storage and destruction service providers, printing house, marketing agency, research companies, IT development and maintenance companies, M Tower management companies.
Auditors, lawyers, tax and legal advisers and any consultants
(4) Our business partners or other third parties as per your consent or contractual requirements or legal requirements, as the case may be.
2.3 Job Applicants, Trainee Applicants and their Reference Persons
2.3.1 Personal Information We Collect, Use or Disclose and Sources of Information
(1) Personal information we collect, use or disclose
Manpower collects several types of personal information, including:
Identity Data (for example, name, surname, identification card number, social security number, passport number, birthdate, gender, age, nationality, marital status,photos, and in some cases Manpower may process sensitive data such as race, religion, blood type, criminal records, health information or disability condition only with your consent or when permitted by law)
Contact Data (for example, address, telephone number, e-mail)
Transaction data (for example, salary)
Other relevant personal data (for example, work experience and educational background, reference person(s), and family members information)
Communication data (for example, images or voice recordings when communicating with us)
(2) Sources of information
Manpower may collect your personal information from various sources as follows:
(a) Collect information directly from you, for example:
Procedures for job or trainee applications, form filling and contract signing, attached documents for selection, questionnaires, or any relevant registrations.
Your communication with us via our contact channels, e.g. telephone, e-mail etc.
Automatic data storage system, e.g. when you use our website or application, etc.
(b) Collect information from other sources, for example:
Reference persons specified in our job and trainee applications
Universities or job recruitment companies
Government authorities or other publicly available sources, such as company websites, job recruitment websites, information made available on the internet or social media platforms, e.g. Facebook, etc.
2.3.2 Purposes of Collection, Use or Disclosure of Personal Information
Manpower collects, uses or discloses your personal information for various purposes depending on relationship between you and Manpower as follows:
Processing purposes |
(a) To proceed as necessary with considering and selecting job or trainee applicants and other relevant procedures, e.g. your application via our website, other job recruitment websites or directly with Manpower, interview procedures, assessment and selection procedures, and/or job offering procedures |
(b) To check your background and qualifications before employment under applicable laws, including checking your criminal records, health records and information from your specified reference persons |
(c) To be benefit for internal human resource management for recruitment process (e.g. disclosing your information or reporting your interview information to relevant divisions and authorized persons for decision making including employment contract preparation and other human resource management procedures) |
(d) To monitor security in our building or premises, including I.D. card deposit before accessing such areas and image recordings within our building or premises via CCTV |
2.3.3 Data Retention Period
Manpower retains your personal information for as long as is considered necessary for the purpose for which it was collected, used or disclosed as set out in this Privacy Notice. In the case where your application is unsuccessful, Manpower will retain your personal information for 2 (two) years for contacting you in case of any suitable job position available for you in the future only with your consent.
2.3.4 Data Disclosure
Manpower may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Notice, to:
(1) Subsidiaries, group companies and any related companies (i.e. (1) a company that holds shares in Manpower and/or a company whose shares are held by Manpower, and (2) a company whose shares are held by the company/companies indicated in (1) herein above whether directly or indirectly) for offering you with any other job position as such company deems suitable for your qualification.
(2) Agencies, service providers and/or subcontractors for any operations of Manpower, e.g. document storage and destruction service providers, IT development and maintenance service providers, etc.
(3) Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials.
(4) Other third parties as per your consent or contractual requirements or legal requirements, as the case may be.
2.4 Employees, Trainees and their Family Members
2.4.1 Personal Information We Collect, Use or Disclose and Sources of Information
(1) Personal information we collect, use or disclose
Manpower collects several types of personal information, including:
Identity Data (for example, name, surname, identification card number, passport number, birthdate, gender, age, nationality, marital status,photos, and in some cases Manpower may process sensitive data such as race, religion, criminal records, fingerprint, health information or disability condition only with your consent or when permitted by law)
Contact Data (for example, address, telephone number, e-mail)
Transaction data (for example, bank account number, salary)
Information relevant to your work(for example, working information, work permit information, work performance evaluation, leave records,medical records, use of our information systems)
Other relevant personal data (for example, work experience and educational background, criminal background checks, information of reference persons and family members, and in some cases Manpower may process family members’ sensitive personal data such as medical records only with their consent)
Images or voice recordings during work performance (for example, recording via CCTV)
Information on participating in activities held by Manpower (for example, static images and videos)
(2) Sources of information
Manpower may collect your personal information from various sources as follows:
(a) Collect information directly from you, for example:
Procedures for entering into employment contract with us, contract signing, contract form filling, documents attached to contract, questionnaires, or any relevant registrations.
Your communication with us via our contact channels, e.g. telephone, e-mail etc.
Automatic data storage system, e.g. when you use our website, our information technology system or our application, etc.
(b) Collect information from other sources, for example:
Reference persons specified in our job applications.
Hospitals providing your pre-employment health check-up and annual health check-up
Government authorities or other publicly available sources, such as company website, job recruitment websites, information made available on the internet or social media platforms, e.g. Facebook, etc.
2.4.2 Purposes of Collection, Use or Disclosure of Personal Information
Manpower collects, uses or discloses your personal information for various purposes depending on relationship between you and Manpower as follows:
Processing purposes |
· To proceed with our employment contract procedures and other relevant agreements between you and Manpower (e.g. non-disclosure agreement, company’s work-related policies and work rules), including any amendments to such contract or relevant agreements |
· To communicate with employees, evaluate your work performance, provide trainings, certifications, and registration for participating in any activities for employees |
· To administer employee remunerations and benefits, including payroll accounting, expense management, applicable tax deduction and social security |
· To perform personnel management, including managing employees and performing our obligations under the employment contract between you and Manpower (e.g. issuing employee card, examining work attendance, managing annual leave, personal business leave or sick leave, etc.), and to perform your obligations under the employment contract between you and Manpower, and to undertake any procedures relating to resignation, employment termination, severance pay, post-employment benefits, and reporting to relevant authorities |
· To manage your health and safety (e.g. examining your pre-employment health check-up result, providing annual health check-up, providing health insurance or other insurance, etc.) |
· To survey your working satisfaction and other information, including your engagement with Manpower for analyzing and developing our working and internal policies and procedures |
· To invite you to participate in any activities held by Manpower and third parties including communication on such activities which your images and voice will be recorded during such activities |
· To conduct business planning, reporting, and forecasting |
· To comply with legal obligations and law enforcement requests, and to report information to government authorities as required by laws |
· To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims |
· To monitor your work performance viaCCTV for surveillance and security purposes during the work performance |
· To monitor security in our building or premises and image recordings within our building or premises via CCTV |
· To manage risks and undertake internal prevention, audit and administration (e.g.investigation of fraud, employees’ disciplinary offences or any other illegal actions, examination of qualifications and professional licenses for certain positions, conflict of interest assessment for certain managing positions, monitoring by supervisory authorities or any other legal proceeding) |
· To disclose to our customers, vendors, supplier or other third parties due to your rights and obligations for work performance under employment contract |
· To disclose to agencies, service providers, subcontractors, and insurer for any operations of Manpower (e.g. providing building entry cards) |
· To disclose your employment information to your prospective employers where you specify Manpower as your referred current employer |
· To disclose to our group companies |
2.4.3 Data Retention Period
Manpower retains your personal information for as long as is considered necessary for the purpose for which it was collected, used or disclosed as set out in this Privacy Notice. The criteria used to determine our retention periods include: we retain the personal information for the duration we have an ongoing relationship with you under employment or internship contract; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be comply with, for any other cause, our internal policies and regulations.
2.4.4 Data Disclosure
Manpower may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Notice, to:
(1) Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials.
(2) Agencies, service providers and/or subcontractors for any operations of Manpower such as
Carriers, document storage and destruction service providers, printing house, marketing agency, IT development companies, building management company.
Auditors, lawyers, tax and legal advisers and any consultants
(3) Hospitals providing pre-employment health check-up and annual health check-up
(4) Our business group or other third parties as per your consent or contractual requirements or legal requirements, as the case may be.
2.5 Others Whose Personal Information Collected, Used or Disclosed by Us
2.5.1 Personal Information We Collect, Useor Disclose and Sources of Information
(1) Personal information we collect, use or disclose
Manpower collects several types of personal information, including:
Identity Data (for example, name, surname, identification card number, passport number, birthdate, gender, age, nationality, marital status,and in some cases Manpower may process sensitive data such as race, religion, health information or disability conditions only with your consent or when permitted by law)
Contact Data (for example address, telephone number, e-mail)
Transaction data (for example, bank account number, income information, transactions related to our products or services)
Communication data (for example, images or voice recordings when communicating with us)
Information related to employment status at Manpower (for example, job position, salary, work performance)
Information on participating in activities held by Manpower (for example, a log of any events, interviews, training, or webinars attended or scheduled)
(2) Sources of information
Manpower may collect your personal information from various sources as follows:
(a) Collect information directly from you, for example:
Procedures for applications for using our services, contract signing, form filling, questionnaires, registrations or submission of claims or requests for exercising your rights
Your communication with us via our contact channels, e.g. telephone, e-mail, etc.
Automatic data storage system, e.g. when you use our website or application, etc.
(b) Collect information from other sources, for example:
Our customers, agents or service providers
Our group companies or our business partners
Government authorities or other publicly available sources, such as company website, information made available on the internet or social media platforms, e.g. Facebook, etc.
2.5.2 Purposes of Collection, Use or Disclosure of Personal Information
Manpower collects, uses or discloses your personal information for various purposes depending on relationship between you and Manpower as follows:
Processing purposes |
· To undertake as per your request or comply with agreement between you and Manpower(e.g. membership application for receiving benefits, participating in any activities of Manpower such as lucky draws, prize trivia quizzes, seminars, trainings, corporate social responsibility activities, reward events, and Manpower youth football player project |
· To comply with our internal procedures, receipt or delivery of information or documents between you and Manpower |
· To survey your satisfaction and to assess and develop our products, services and sales promotion |
· To invite you to participate in any activities held by Manpower or third parties including communication on such activities which your images and voice will be recorded during such activities |
· To comply with legal obligations and law enforcement requests, and to report or disclose information to government authorities as required by laws |
· To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims |
· To monitor security in our building or premises, including I.D. card deposit before accessing such areas and image recordings within our building or premises via CCTV |
· To manage risks and undertake internal audit and administration |
· To disclose to our agencies, service providers and/or subcontractors for undertaking any activities and projects of Manpower, and to survey your satisfaction in such activities and projects |
· To undertake any procedures relating to resignation, employment termination, severance pay, post-employment benefits and reporting to relevant authorities |
· To disclose your employment information to your prospective employers where you specify Manpower as your referred former employer |
2.5.3 Data Retention Period
Manpower retains your personal information for as long as is considered necessary for the purpose for which it was collected, used or disclosed as set out in this Privacy Notice. The criteria used to determine our retention periods include: we retain the personal information for the duration we have an ongoing relationship with you and provide the service to you; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be comply with, for any other cause, our internal policies and regulations.
2.5.4 Data Disclosure
Manpower may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Notice, to:
(1) Subsidiaries, group companies and any related companies (i.e. (1) a company that holds shares in Manpower and/or a company whose shares are held by Manpower, and/or (2) a company whose shares are held by the company/companies indicated in (1) hereinabove whether directly or indirectly) for business purposes, internal management, offering for sale of products and services which you may be interested in, including undertaking any other activity as set out in this Privacy Notice.
(2) Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials.
(3) Agencies, contractors/subcontractors and/or service providers for any operations of Manpower such as
Carriers, providers of card issuing or destruction,document storage and destruction service providers, printing house, marketing agency, research companies, IT development and maintenance companies, travel and accommodation services companies
Auditors, lawyers, tax and legal advisers and any consultants
Our business partners or other third parties as per your consent or contractual requirements or legal requirements, as the case may be.
3. Lawful Basis for Processing of Personal Data
Manpower only processes your personal information as it is necessary for the scope set out in this Privacy Notice, as follows:
To take steps at your request prior to entering into a contract and to perform contractual obligations between you and Manpower;
Where it is necessary to comply with legal or regulatory obligations which Manpower is subject to;
Where it is necessary for legitimate interests of Manpower, except where such interests are overridden by the interests or fundamental rights and freedom of an individual;
Where we obtain your explicit consent (as required by law only); or
Where it is necessary for establishment, compliance, exercise or defense of the rights to legal claims.
In the case where the personal information collected by Manpower as stated above is necessary for Manpower’s performance of contract or compliance with applicable laws and you do not provide us with such necessary personal information, Manpower may be subject to legal liabilities and/or may not be able to manage or administer the contract or give any convenience for you.
4. Your Rights as a Data Subject
4.1 Your rights under the PDPA
According to the PDPA, you have certain rights relating to your personal information as follows:
(1) Right to Withdraw Consent
You have the right to withdraw consent given to us for collecting, using or disclosing your personal information at any time, unless there is a restriction of the withdrawal of consent by law or the contract which gives benefits to you.
However, the withdrawal of consent shall not affect the collection, use or disclosure of personal information you have already given consent legally. In addition, where you withdraw consent, you may experience less convenient in using our products or services, or may not receive our benefits or special offers, or may experience other effects in using our products or services.
(2) Right to Access
You have the right to request access to and obtain copy of your personal information, which is under our responsibility, or to request the disclosure of the acquisition of the personal information obtained without your consent.
(3) Right to Data Portability
Where Manpower arranges your personal information to be in the format which is readable or commonly used by ways of automatictools or equipment, and can be used or disclosed by automated means, you have the right to receive your personal information and are also entitled to:
(a) request us to send or transfer your personal information in such formats to other data controllers if it can be done by the automatic means;
(b) request to directly obtain your personal information in such formats that we send or transfer to other data controllers, unless it is impossible to do so because of the technical circumstances.
(4) Right to Object
You have the right to object to the collection, use or disclosure of your personal information for direct marketing purposes or on grounds stipulated by law.
(5) Right to Erasure
You have the right to request Manpower to erase, destroy or make your personal information become unidentifiable data, when permitted by law.
(6) Right to Restriction of Processing
You have the right to request Manpower to restrict the use of your personal information when permitted by law.
(7) Right to Rectification
Manpower will ensure that your personal information remains accurate, up-to-date, complete, and not misleading. However, if you consider that your personal information is inaccurate or changed, you have the right to request Manpower to modify your personal information to be accurate, up-to-date, complete, and not misleading.
(8) Right to Complaint
You have the right to file a complaint to a competent official under the PDPA anytime Manpower violates or does not comply with the PDPA.
4.2 How to exercise your rights
You may exercise the data subject rights listed above via the following channels:
E-mail: [email protected]
Data Subject Request Form (via this website)
One of our team may contact you directly, or via our secure online portal, to verify your email address and thereafter your identity, before Manpower provides access, modifies, or erases your data. As part of this ID verification process, you may be asked to provide a government issued ID and/or passport. Manpower will permanently delete the verification information that you provide promptly after Manpower has completed the verification process.
Manpoweris only required to respond to requests that are verifiable and legitimate. If Manpower cannot verify your identity based on the processes described above, Manpower may ask you for additional verification information. Manpower will not use that information for any purpose other than verification. If Manpower cannot verify your identity to a sufficient level of certainty to respond to your request, Manpower will let you know promptly and explain why Manpower cannot verify your identity and process your request.
4.3 Authorized Representativeof the Data Subject
You may designate an authorized representative to exercise your rights on your behalf. If an authorized representative submits a request on your behalf, they must also submit a document signed by you that authorizes your representative to submit the request on your behalf.
In addition, Manpower may ask that both you and your representative, follow the applicable process described above for identity verification.
5. ManpowerGroup’s Non-Discrimination Policy
Users of our Sites and services will not be subject to discriminatory treatment for exercising their privacy rights. Please bear in mind that exercising some rights, like erasure, consent withdrawal or your right to object, may affect our ability to carry out and deliver some, or all, of the services you are eligible for.
6. Personal Data Protection Security Measures
6.1 Implementation of Security Measures
Manpower maintains administrative, technical, and physical safeguards designed to protect the personal data. Manpower collects against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Such measures are designed to provide an appropriate level of security taking into account, on one hand, the technical state of the art and, on the other hand, the sensitivity of the personal data and the evaluation of potential risks.
To provide the appropriate security and confidentiality of personal data, Manpower applies the following non-exhaustive list of measures, as appropriate:
Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths;
Strong user authentication and role-based access controls;
Network monitoring solutions with events logging;
Hardened network infrastructure;
Measures for ensuring physical security of locations at which personal data are processed;
Business continuity and disaster recovery plans with periodic testing;
Incident management policy and processes;
Periodic vulnerability and penetration testing;
Certification/assurance of processes and products;
Periodic employee privacy and security training and awareness program;
Third party privacy and security assessments;
Robust data processing and confidentiality agreements; and
Organizational measures for ensuring data minimization, purpose limitation, retention, data quality and accountability.
6.2 Disclosure of Personal Information to Data Processor
Manpower properly supervises third parties to which Manpower has appointed to process personal information pursuant to our orders or on our behalf.
7. Data Transfers
Manpower also may transfer the personal data Manpower collects about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data.
When Manpower transfers your information to other countries, Manpower will protect that data as described in this Privacy Notice and any other specific notice given to you at the time of, or prior to, the processing.Such transfers will comply with applicable law.
When Manpower transfers personal data from within the European Economic Area, the United Kingdom or Switzerland, to countries that do not benefit from Adequacy Agreements, transfers will take place on the basis of:
a) a legally binding and enforceable instrument between public authorities or bodies;
b)binding corporate rules;
c) standard contractual clauses (SCCs) adopted by the European Commission, along with the mandatory adoption provisions required for the UK and Switzerland to the extent the processing involves UK or Swiss residents.
Where transfers rely on SCCs, transfers will only take place after a transfer impact assessment of;
(1)The legal practices of the recipient country relating to access to data;
(2)The technical and organizational measures adopted to protect the data; and
(3)The nature of the processing to ensure purpose limitation and data minimization.
Subject to applicable law, you may obtain a copy of these safeguards by contacting us as indicated in the contact information section below.
8. Artificial Intelligence (AI) / Machine Learning (ML)
9. Contact information
If you have any questions or inquiries about the protection of your personal information, collection, use or disclosure of your personal information, or exercise of your rights, or have any claims, please submit a request through our Privacy Request Portal.
Alternatively, you can contact us at:
Skillpower Services (Thailand) Company Limited and Data Protection Officer
Address: Skillpower Services (Thailand) Company Limited
No. 31, 31/1, 33 Bhiraj Tower at Sathon Building B, 2nd Floor, South-Sathorn Road. Yannawa Sub-District, Sathorn District, Bangkok 10120
Tel: +66 2 1712399
E-mail: [email protected]
10. Link to Third Party Websites via Manpower Website
This Privacy Notice applies to the sales of products or provision of services and use of Website of Manpower only. When you link to third party websites via Manpower Website, the personal information protection shall be in accordance with the Privacy Notice of such third party websites which are not related to Manpower. Manpower does not disclose your personal information to organizations operating such linked third-party websites and Manpower does not review or endorse, and is not responsible for, the privacy practices of these organizations. Manpower encourages you to read the privacy policy of each website that you visit. This privacy notice applies solely to information collected by Manpower and its subsidiaries and affiliates through the services.
11. Update to this Privacy Notice
Manpower regularly reviews and, if appropriate, updates this Privacy Notice from time to time to ensure that your personal information is properly protected. In case of any significant update to this Privacy Notice, Manpower will inform you through the appropriate channel(s).
[Last updated on 14/10/2024]