PRIVACY POLICY - HONG KONG
Your privacy is important to Bluemont Consulting
Your privacy is important to us. This statement outlines Bluemont Consulting’s privacy policy on when and how we collect personal data and how we maintain, use, store, transfer and disclose the personal data we hold. It applies to all operations within Stirling Andersen Hong Kong Limited (‘Bluemont Consulting’), including visitors to our website.
It is the policy of Bluemont Consulting to respect the confidentiality of personal data and the privacy of individuals. Bluemont Consulting is bound by the Personal Data (Privacy) Ordinance (Cap. 486) and its amendment Ordinance of the laws of the Hong Kong Special Administrative Region.
The Bluemont Consulting privacy policy will be reviewed and updated from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Please regularly check our privacy policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of our privacy policy.
The Bluemont Consulting privacy policy is based on transparency
We are committed to being open and transparent about how we manage personal information.
Types of personal data held by Bluemont Consulting
Personal data means any type of information (i) relating directly or indirectly to a specific living individual; (ii) from which enables it is practicable for the identity of the individual to be directly or indirectly ascertained; and (iii) in a form in which access to or processing of the data is practicable.
Personal data may include:
- Name
- IC number
- Employer
- Photo page of passport
- Visa details
- Date of birth
- Contact details
- Emergency contact details
- Work telephone number
- Work email address
- Work experience
- Qualifications
- Aptitude test results
- Opinions about your work performance (eg references)
- Incidents at the workplace
- Other personal data obtained or received by us in connection with your possible and actual work placements
- Personal data associated with managing queries and complaints
This policy applies to all data we process about you and may include some data about your physical or mental health or condition, political opinions, religious or similar beliefs, commission or allegations of an offence and other sensitive personal data. References to personal data in this policy include such sensitive personal data.
When & how personal data is collected
Personal data should not be collected unless:
- The data is collected for a lawful purpose directly related to a function or activity of Bluemont Consulting
- The collection of data is necessary for or directly related to that purpose
- The data is adequate but not excessive in relation to that purpose
Standard personal data collection
We may collect personal data about you when:
- You complete the Bluemont Consulting registration forms or provide any other information in connection with your application
- We receive any reference about you
- We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
- We receive the results of any competency or medical test or any background check
- We receive any complaint or other information from or about you in the workplace
- We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved
- We receive any information about a workplace accident in which you are involved
- You provide us with any additional information about you
General information collected from visitors to our website
We gather information about all our website users collectively, such as what areas users visit more frequently and what services users access the most. We only use such data anonymously and in the aggregate. This data helps us determine what is most beneficial for our users, and how we can continually create a better overall website experience for you.
Your personal data collected on the bluemontconsulting.com.hk website
In some instances we may need specific data about you, such as name, address, email address, telephone number etc. We will collect this data if you apply for a job or sign up for a service via our website. We may also ask you for other data such as the types of jobs you are interested in and your workplace concerns in order to provide you with the best possible service and internet experience.
Purposes for which we collect personal data
Provision of services
Please note that it is mandatory for you to provide us with such personal data in order for us to be able to provide you with our services.
Your personal data may be used in connection with:
- Your actual or possible work placement
- Career guidance or management
- Your performance appraisals
- Our assessment of your ongoing performance and prospects
- Any test or assessment (including medical tests and assessments) that you might be required to undergo
- Our identification of your training needs
- Any workplace rehabilitation
- Our management and resolution of any complaint, inquiry or investigation in which you are involved
- Any insurance claim or proposal that requires disclosure of your personal or sensitive information
- Undertaking criminal reference checks
- For research, development, business systems and infrastructure testing, and other business purposes to assist us in providing our services to you
- Providing our services to our clients
Direct marketing
Where we have obtained your consent (eg by you agreeing in writing to our Privacy Notice) or are otherwise lawfully allowed to do so, we intend to use your name, residential address, mobile phone number, residential home number and email address to promote Bluemont Consulting recruitment and training services and events, by phone, SMS/MMS, email or post as further described in this policy.
We cannot use or provide your personal data for use in direct marketing unless we receive your consent to the intended use or provision or have another lawful basis.
If at any time you provide personal data of a third party to us, you warrant and represent that:
- You have already given written notice to the third party of the intention to use the data for such direct marketing
- Have obtained the; written consent of the third party to the use or provision of their personal data in such direct marketing by Bluemont Consulting
- The intended use of personal data by Bluemont Consulting and the promotion of [Bluemont Consulting recruitment services] is consistent with and covered by the consent of the third party
Disclosures
We may disclose your personal data for the purposes for which it is collected. Your personal data may be disclosed to:
- Potential and actual employers and clients of Bluemont Consulting
- Bluemont Consulting employees and potential employers globally
- Referees
- External providers of on-line training and induction - eg mandatory on-line H&S Induction
- Our insurers and brokers
- A professional association or registration body that has a legitimate interest in the disclosure of your personal and sensitive information
- A Workers Compensation body
- Any person with a lawful entitlement to obtain the information
- Accountants, auditors, company secretarial services and professional advisers
- Landlords, agents and property services organisations
- Travel and other services providers
- IT, data, network, technology, internet, social network and business process service providers and organisations
- Marketing and event organisers, venues and companies
This may include transferring your personal data to a location or country which may not offer the same level of protection of personal data as Hong Kong.
We do not disclose data about your individual visits to the Bluemont Consulting website website.
Management of personal data
At Bluemont Consulting, we train our staff to respect the confidentiality of customer information and the privacy of individuals. Bluemont Consulting regard breaches of your privacy seriously and any breach will result in disciplinary action being taken, dependent upon severity.
How do we store & protect personal data?
Safeguarding the privacy of your personal data is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium. We hold personal data in a combination of secure computer storage facilities and paper-based files and other records, and take such steps as are reasonable in the circumstances to protect the personal data we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider data is no longer needed for the fulfilment of the purpose (including any directly related purpose) for which the data is or is to be used, we will remove any details that will identify you or we will securely destroy the records.
How do we keep personal data accurate & up to date?
Bluemont Consulting take reasonable steps to ensure that the personal information it holds and discloses is accurate up to date and complete. We recognise that personal data changes frequently with changes of address and other personal circumstances. We generally update your customer data over the telephone. Please advise your consultant when your personal details change.
If you have created a profile with Bluemont Consulting via our website, you are able to review and edit your personal data at any time by logging into your account and reviewing your profile. You can delete your personal information or close your account by contacting the Privacy Officer. If you do choose to close your account with Bluemont Consulting, Bluemont Consulting may retain personal information from your account as and where required by law.
Enquiries & complaints
You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches to, or otherwise contact our Privacy Officer:
Email: tom@bluemontconsulting.com.hk
Address: 19/F workstation, 43 Lyndhurst terrace, Central Hong Kong
Access
Subject to some exceptions that are set out in the Personal Data (Privacy) Ordinance you can gain access to the personal data that we hold about you.
To make a request to access your personal data, you will need to complete an application form verifying your identity and specifying what information you require. Please contact our Privacy Officer for an application form. We will respond to your request within 40 days after the request is made and provide access to the information in the manner requested.
We may impose a moderate charge in providing access. Our Privacy Officer will discuss this with you if we refuse to provide you with access to your personal data in accordance with the Personal Data (Privacy) Ordinance, we will notify you in writing of the reasons for the refusal and the process for escalation regarding this refusal.
Correction
You may request that we correct the personal data that we hold about you if you deem it to be inaccurate, incomplete, out-of-date, irrelevant or misleading. We will:
- make the necessary correction to that data
- supply to you with a copy of the data as so corrected
PRIVACY NOTICE - HONG KONG
As part of our compliance with the Personal Data (Privacy) Ordinance (Cap. 486) (‘PDPO’) of the laws of the Hong Kong Special Administrative Region, Stirling Andersen Hong Kong Limited requests you read the following information regarding when and how we collect your personal data and how we maintain, use, store, transfer and disclose of your personal data in connection with your possible or actual work placements and sign where indicated to acknowledge your acceptance and understanding of this information.
Personal data means information about you, including your work experience, qualifications, aptitude test results, opinions about your work performance (eg references) and other information obtained by us in connection with your possible work placements
We may collect personal data about you when:
- You complete our registration forms or provide any other information in connection with your application
- We receive any reference about you
- We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
- We receive the results of any competency or medical test or background checks
- We receive any complaint or other information from or about you in the workplace
- We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved
- We receive any information about a workplace accident in which you are involved
- You provide us with any additional information about you
Please note that it is mandatory for you to provide personal data in order for us to be able to provide you with our services.
Your personal data may be used in connection with:
- Your actual or possible work placement, career guidance or management
- Your performance appraisals
- Our assessment of your ongoing performance and prospects
- Any test or assessment (including medical tests and assessments) that you might be required to undergo
- Our identification of your training needs
- Any workplace rehabilitation
- Our management and resolution of any complaint, inquiry or investigation in which you are involved
- Any insurance claim or proposal that requires disclosure of your personal information
- Undertaking criminal reference checks
Your personal data may be disclosed to:
- Potential and actual employers and clients of Bluemont Consulting
- IT, data, network, technology, internet, social network and business process service providers and organisations
- Bluemont Consulting employees and potential employers located globally
- Referees
- External providers of online training and induction eg mandatory on-line OH&S Induction
- Our insurers and brokers
- A professional association or registration body that has a proper interest in the disclosure of your personal data
- A Workers Compensation body
- Any person with a lawful entitlement to obtain the information
- Accountants, auditors, company secretarial services and professional advisers
- Landlords, agents and property services organisations
- Travel and other services providers
- Marketing and event organisers, venues and companies
This may include transferring your personal data to a location or country which may not offer the same level of protection of personal data as Hong Kong.
If you do not give us the information we seek:
- We may be limited in our ability to locate suitable work for you; and
- We may be limited in our ability to place you in work