This Data Protection Notice ("Notice") sets out the basis upon which Sequoia Solutions Sdn Bhd ("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.
APPLICATION OF THIS NOTICE
1. This Notice applies to all persons who have applied as a job applicant with us, visitor, customer, employee and general public.
PERSONAL DATA
2. As used in this Notice, "personal data" means data and/or information about you, whether true or not, from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Personal Data include, but are not limited to:
(a) Your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
(b) your photos or video footage;
(c) your employment history, education background, and income levels;
(d) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally collect personal data that:
(a) 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,
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws, or
(c) CCTV images of you are recorded for the purpose of crime prevention and personal safety. 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).
5. Generally, we collect personal data in the following ways:
(a) when you submit any form, including but not limited to application and registration forms or other forms relating to any of our Products or Services;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Products and Services;
(c) when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
(d) when you use our electronic services, or interact with us via our websites, and apps or use services on our websites;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment or any other position.
(g) when your images are captured by us via CCTV cameras or face recognition system while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
(h) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(i) when we receive references from business partners and third parties, for example, where you have been referred by them with your consent;
(j) when we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our Products and Services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
(k) when you submit your Personal Data to us for any other reasons.
6. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes and ensure the personal data provided is accurate and complete.
7. If you provide us with personal data of another person, you represent and warrant to us that you have been appointed and authorized by the other person to act on his behalf. This includes providing consent to our collection, use, disclosure, transfer and retention of his personal information and sensitive personal information and that the data is accurate and complete.
8. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested, or delays in processing your applications.
9. However, when you voluntarily provide personal data to us for a purpose and it is reasonable that you do so we may rely on you being deemed to have consented to us collecting, using and disclosing your personal data for that purpose.
10. Under certain circumstances, we may collect, use and/or disclose personal data about you without your consent for example, so that we can comply with our statutory obligations or where personal data is publicly available.
11. Your personal data will be collected and used by us for the following purposes, and we may disclose your personal data to third parties where necessary for the following purposes:
(a) performing obligations in the course of or in connection with our provision of services requested by you;
(b) in the event of contact tracing;
(c) verifying your identity and security;
(d) employment and job application;
(e) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(f) managing your relationship with us;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(h) any other purposes for which you have provided the information;
(i) any other incidental business purposes related to or in connection with the above.
12. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
13. After the lapse of the opt-out period, 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 those purposes.
14. When and if there's new need and purpose to use and disclose your personal information to any organisation that's not related to any employment purposes and outside the Company, the HR/Admin team will request for your consent, and you will be notify on the purpose of use or disclosure of your personal data with the Company, you will also be notify the consequences of refusal to give your consent.
WITHHOLDING OF CONSENT
19. 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. 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.
20. 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 Thirty (30) days of receiving it.
21. 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 request. We shall, in such circumstances, notify you before completing the processing of your request of withdrawal. Should you decide to cancel your withdrawal of consent, please inform us in writing via email.
22. 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 PERSONAL DATA
23. If you wish to make 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
24. 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.
25. We will respond to your request as soon as reasonably possible. In general, our response will be within Thirty (30) 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).
26. In the event that access request is rejected, and if you are dissatisfied with the organisation refusal to access the data – you may write to our Data Protection Officer again to highlight your objection and our Data Protection Officer will escalate to higher management to review the decision and ground to reject your request. Our Data Protection Officer will endeavour to revert to you within Thirty (30) days.
27. 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.
CORRECTION TO PERSONAL DATA
28. If you wish to make 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.
29. We will respond to your request as soon as reasonably possible. In general, our response will be within Thirty (30) business days. Should we not be able to respond to your access request 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).
30. In the event a correction request is rejected, and if you are dissatisfied with the organisation's refusal to correct the data – you may write to our Data Protection Officer again to highlight your objection and our Data Protection Officer will escalate to higher management to review the decision and ground to reject your request. Our Data Protection Officer will endeavour to revert to you within Thirty (30) days.
31. 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.
32. Once correction to personal data is done, organisation will communicate the corrections to third parties to whom the personal data was disclosed.
PROTECTION OF PERSONAL DATA
33. 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 such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, security review and testing performed regularly.
34. 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.
ACCURACY OF PERSONAL DATA
35. 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
36. 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.
37. 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
38. We do not transfer your personal data to countries outside of Malaysia. 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.
DATA PROTECTION OFFICER
39. You may contact our Data Protection Officer if you have any enquiries or feedback, complaints and dispute on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:
Phone : +60 122071351
Email : dpo@sequoia-asia.com
EFFECTS OF NOTICE AND CHANGES TO NOTICE
40. This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
41. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.
PERSONAL DATA COLLECTION FOR BeauteSoft CRM PLATFORM
42. We may collect various types of personal data from users, including but not limited to:
(a) Name, identification number, and contact details
(b) Employment details, salary, and benefits information
(c) Attendance, leave, and claims records
(d) Any other personal data provided by users or collected in the course of using our BeauteSoft CRM Platform
PURPOSES OF COLLECTION FOR BeauteSoft CRM PLATFORM
43. For users of our BeauteSoft CRM platform, we collect personal data for additional purposes such as:
(a) To provide and maintain our BeauteSoft CRM Platform
(b) To manage and administer user accounts
(c) To generate reports and analytics for business and HR decision-making
(d) To communicate with users, including providing notifications, alerts, and support
(e) To comply with applicable laws and regulations
(f) Any other purposes disclosed at the time of collection
DISCLOSURE OF PERSONAL DATA FOR BeauteSoft CRM PLATFORM
44. We may disclose personal data to:
(a) Our affiliated companies and subsidiaries
(b) Third-party service providers engaged to perform services on our behalf
(c) Government or regulatory authorities as required by law
(d) Any other parties with the user's consent or as permitted under the PDPA
TRANSFERS OF PERSONAL DATA
45. We do not transfer your personal data to countries outside of Malaysia. 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.
SECURITY AND RETENTION FOR BeauteSoft CRM PLATFORM
46. We take appropriate measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. Personal data will be retained for as long as necessary for the purposes stated in this Addendum and the main PDPA Policy or as required by applicable laws.
ASSESS AND CORRECTION FOR BeauteSoft CRM PLATFORM USERS
47. BeauteSoft CRM Platform users have the right to access and correct their personal data held by us. This can be done by their company appointed Administrator or Super Admin in the BeauteSoft CRM Platform.
Last Updated: 29th January 2024