Effective from March 29, 2023

DATA PROTECTION NOTICE FOR JOB APPLICANTS

1. This Data Protection Notice (“Notice”) sets out the basis upon which Edge Tutor International Pte. Ltd. (“we,” “us” or “our”) may collect, use, disclose, or otherwise process personal data of job applicants 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 organizations which we have engaged to collect, use, disclose, or process personal data for our purposes.

APPLICATION OF THIS NOTICE

2. This Notice applies to all persons who have applied for any such position with us (“job applicants”).

PERSONAL DATA

3. As used in this Notice, “personal data” means data, whether true or not, about an employee or a job applicant 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 which we may collect includes, without limitation, your:

(a) name or alias, gender, last 4 characters of your NRIC/FIN or passport number,
date of birth, nationality, and country and city of birth;

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

(d) employment and training history;

(e) salary information and bank account details;

(f) details of your next-of-kin, spouse and other family members; and

(g) photographs.

4. 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

5. 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 with us, or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”, which may include your job placement agent), after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized 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 authorized by law).

6. 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) assessing and evaluating your suitability for employment in any current or prospective position within the organization
(b) verifying your identity and the accuracy of your personal details and other information provided;

(c) performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;

(d) managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;

(e) assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organization;

(f) ensuring business continuity for our organization in the event that your employment with us is or will be terminated;

(g) performing obligations under or in connection with the provision of our goods or services to our clients; and

(h) facilitating our compliance with any laws, customs and regulations which may be applicable to us.

7. 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).

8. 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.

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

9. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Edge Tutor International Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Edge Tutor International Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

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

a. Fraud detection and prevention; and
b. Detection and prevention of misuse of services.

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

11. 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.

12. 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 twenty (20) days of receiving it.

13. While 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 8 above.

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

ACCESS TO AND CORRECTION OF PERSONAL DATA

15. 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.

16. 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.

17. We will respond to your request as soon as reasonably possible. In general, our response will be within twenty (20) 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).

18. 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 organization has on record, if the record of your personal data forms a negligible part of the document.

PROTECTION OF PERSONAL DATA

19. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimized collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), regular patching of operating system and other software, web security measures against risks, and security review and testing performed regularly.

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

21. We generally rely on personal data provided by you (or your authorized 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

22. We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.

23. 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

24. 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.

DATA PROTECTION OFFICER

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

Name of DPO: Misael Sigua
Contact No.: 639178595519
Email Address: msigua@edgetutor.co
Address: 600 North Bridge Road

EFFECT OF NOTICE AND CHANGES TO NOTICE

26. 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.

27. 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. Your continued employment and participation in our recruitment process constitute your acknowledgment and acceptance of such changes.

BUSINESS-TO-BUSINESS DATA PRIVACY POLICY FOR CLIENT'S OWN TEACHING PLATFORM

This Data Privacy Policy governs the handling of data in the context of business-to-business (B2B) interactions where our clients utilize their own teaching platform.

1. Scope and Application

This policy applies to all data exchanged, collected, or processed in B2B interactions where our clients utilize their own teaching platform for educational purposes.

2. Data Handling

We acknowledge that our clients maintain control over the data collected and processed within their own teaching platforms. Our role is limited to providing services, support, and integration with these platforms.

3. Data Protection

While we do not control the data within the client's teaching platform, we are committed to assisting our clients in ensuring data protection. We take reasonable technical and organizational measures to safeguard any data shared during B2B interactions. EDGE Tutor International is Data Privacy Act (DPA) compliant in the Philippines.

4. Third-Party Integration

In some cases, third-party services or tools may be integrated with the client's teaching platform. It is the client's responsibility to review and agree to the data handling practices of these third parties.

5. Compliance

We are committed to complying with relevant data protection laws and regulations within the scope of our services. Clients are responsible for ensuring their use of their teaching platform complies with applicable data protection requirements.

6. Client Responsibilities

Clients are responsible for obtaining any necessary consents and permissions for data processing within their teaching platform. They must also adhere to any contractual obligations and privacy notices provided to their users.

7. Changes to this Policy

We may update this B2B Data Privacy Policy as necessary. Clients will be notified of significant changes. Continued use of our services in B2B interactions signifies agreement with the updated policy.

8. Contact Us

For questions, concerns, or requests related to data privacy in B2B interactions, you may contact our Data Protection Officer:

Name of DPO: Misael Sigua
Contact No.: 639178595519
Email Address: msigua@edgetutor.co
Address: 600 North Bridge Road

By engaging in B2B interactions with us and utilizing your own teaching platform, you acknowledge that you have read, understood, and agreed to the terms of this Data Privacy Policy. By using EDGE Tutor Services, you acknowledge that you have read and understood this Data Privacy Policy and agree to the collection, use, and storage of your basic personal information as outlined herein.

SAFEGUARDING POLICY

At EDGE TUTOR INTERNATIONAL PTE. LTD., we are committed to providing a safe and nurturing environment for children and ensuring their protection from all forms of abuse, neglect, harm, or exploitation. This Child Safeguarding Policy outlines our commitment, guidelines, and procedures to safeguard the well-being of children under our care.

1. Commitment

We are dedicated to creating a culture that prioritizes the safety and well-being of children and young people. Our commitment includes:

Treating all children and all individuals with respect, dignity, and kindness.
Taking immediate action to address any concerns or suspicions of abuse.
Implementing measures to prevent abuse and ensure children's protection.

2. Code of Conduct

All staff, volunteers, contractors, and individuals associated with EDGE TUTOR INTERNATIONAL PTE. LTD. are required to adhere to a strict code of conduct when interacting with children or any individuals. This includes:

Treating children with respect and listening to their concerns.
Avoiding any form of abusive, harmful, or exploitative behavior.
Maintaining professional boundaries and avoiding situations that could be misinterpreted.
Avoiding to discuss any taboo topics under PARSNIP

3. Recruitment and Training

All individuals working with EDGE TUTOR INTERNATIONAL PTE. LTD will undergo thorough background checks and must submit a valid NBI clearance. NBI clearance is a document issued by the Philippines' National Bureau of Investigation that confirms that an individual is not involved in any criminal activity in the country.
Mandatory child safeguarding training will be provided to all staff and volunteers, covering topics such as recognizing signs of abuse, reporting procedures, and maintaining a safe environment for all learners.

4. Reporting and Mechanisms and Responding to Concerns

Reporting Concerns:

We empower our staff and tutors to promptly report any concerns or incidents related to child safeguarding to our safeguarding lead. Whether it's recognizing a potential risk, responding to a worrying situation, or directly reporting an incident, our reporting mechanisms are designed to facilitate swift action.

Confidentiality and Swift Action:

Any reports made through our designated reporting channels will be handled with the utmost confidentiality. We prioritize protecting the identities of all parties involved. Upon receiving a report, our team will take immediate and appropriate action through collaboration with our partner agencies.

Collaboration with Partner Agencies:

In cases where additional support is needed, we collaborate closely with trusted partner agencies. This collaborative approach ensures that comprehensive actions are taken to address any concerns and prioritize the safety and well-being of children and young people.

5. Review and Monitoring

This Safeguarding Policy will be regularly reviewed and updated to reflect changes in laws, regulations, and best practices. Feedback from stakeholders will be considered to improve our safeguarding measures.

6. Contact Us

For any questions, concerns, or reports related to safeguarding, please contact our designated safeguarding officer at core@edgetutor.co

Effective date: 05/01/2024
Last updated: 05/01/2024