Privacy Notice
for Human Resources and Talent Acquisition

transcosmos (Thailand) Co., Ltd. (the “Company”) have created this Privacy Notice (the “Notice”) in compliance with the responsibilities of data controller as indicated in Personal Data Protection Act B.E.2562. The purpose of this Notice is to describe how we collect, use, disclose, and/or transfer your personal data. This Notice also tells you about your rights and choices with respect to your personal data as a data subject, and how you can reach us to get answers to your questions.

This Notice is addressed to individuals with whom we interact and whose personal data we handle for the purposes indicated in this Notice, including our (i) candidates (ii) employees including short-term employee, (iii) director, and (iv) any other individuals about whom we obtain personal data (e.g. family members, references, guarantors, beneficiaries, emergency contact persons, related persons, and etc.) (together, “you” or “your”).

1. Definition

“Personal Data” means any identified or identifiable information about you as listed below. If it is possible to combine any information with your Personal Data, or if other information is used to build a profile of an individual, we will treat such other information and combined information as Personal Data.

2. Personal data that we collect

We may collect or obtain the following categories of information which may include your Personal Data, depending on the context of your interactions with us, our contract to employment/ work relationship, and the type of data subject you are to us, as follows:

(1) Your information you are known, addressed, or referred to such as, title, first name/initial, middle name/initial, last name, maiden name, aliases or previous names, signature.

(2) Personal details about you such as, age, date of birth, gender, height, weight, marital status, nationality, country of birth, citizenship, citizenship status, military details, leisure activities and interests, photographs, language skills, number of children, moving picture and/or voice recording in different formats such as video or live broadcast.

(3) Your contact details such as, home postal address, delivery address, home telephone number, home facsimile number, personal electronic mail address, personal cellular, mobile or wireless number, social media profile/handle, business postal address, business telephone number, business facsimile number, business electronic mail address, business cellular, mobile or wireless number.

(4) Your educational and professional information such as, degrees and schooling, licenses and professional membership, academic record.

(5) Your employment details, status and history such as, occupation/title, position, function, employer identification number, job code, work permit status, name, employment records (including salary and benefits), recruitment date, length of service, work termination.

(6) A number or code given to you by competent authority to identify who you are such as, national identification number, taxpayer identification number, other government-issued identification number, driver’s or operation’s license number, national identifiers for professional licenses, passport number, foreign registration number.

(7) Your financial information such as, information relating to background checks; financial institution account number, financial transaction history, credit history, source of income, income, salary, service fees, other compensation,

If you do not provide your Personal Data, it may mean that we cannot provide you with the job position you request, we cannot meet all our obligations with respect to contract to employment/ compensation management/ benefit management/ payment of salary, wage and benefits/ training and development / succession plan and talent management/ work relationship with you, or we cannot comply with our legal obligations.

The Company shall collect your sensitive personal data based on Article 26 of Personal Data Protection Act B.E.2562. For example, nationality, race, political opinion, religious beliefs, sexual orientation, criminal record, health information, disability, biological data, biometrics or other similar data. The Company shall access, disclose or control said data with utmost importance and shall inform you about the details of data collection or usage when we collect the data from you.

Personal Data of third parties

If you provide us Personal Data of other persons such as, your mother’s maiden name, spouse’s information, family members’ information, children’s information, information of sponsors or dependents, information of the company’s board members /directors /shareholders / representatives/chief managers, guarantor’s information, beneficiary’s information, or you ask us to disclose their Personal Data to third parties, you are responsible for notifying those other persons of the details of this Notice, including obtaining any required consent from such third parties (where consent is required). You must also ensure that The Company can lawfully collect, use, or disclose those persons’ Personal Data as set out in this Notice

3. Collection of your Personal Data

We may obtain your Personal Data directly from you or indirectly from other sources (e.g., publicly available sources), and/or through our affiliates, recruitment service providers or platforms (including recruiters, headhunters, recruitment websites, social media platforms, event organizers) Mainly, the Company will not collect your personal data from outsiders and only collect information directly from you. However, in case that the Company collect your personal data from outsiders, the Company will ensure that it is in compliance with the Personal Data Protection Act B.E.2562 or other relevant laws.

4. Purposes and legal basis which the Company collect, use, or disclose your Personal Data

  • To perform pre-employment process, such as booking an interview, evaluating and reporting the hiring results, etc.
  • To perform on-boarding process, such as preparing employment contract, conducting new-hire orientation, submitting request for work permit or visa, creating payroll account, adding employee to social security plan / group insurance, checking criminal record and issuing employee card, etc.
  • To perform tasks during the employee’s tenure, such as evaluating, planning payroll and compensation, to deduct compulsory and voluntary taxation and contributions, to process insurance claims, adjusting salary, considering position raise, preparing annual health check-up, conducting internal and external training session, creating working performance report, creating working account, preparing company activities, and communicate about company activities, etc.
  • To process on off-boarding such as, to process post-employment services, certifications, cessation/termination of employment, exit interviews and ad hoc surveys.
  • To protect the Company’s legitimate interests such as, protect the security and integrity of our business, to exercise our rights or protect our interest where it is necessary and lawfully to do so, for example, to detect, prevent, and respond to fraud claims, and to determine fraud risk and identify fraudulent transactions, intellectual property infringement claims, or violations of law, to manage and prevent loss of our assets and property, to perform risk management, internal audits and records, asset management, system, and other business controls, to prevent or suppress a danger to a person’s life, body, or health, to secure the compliance of our terms and conditions, to follow up on incidents, to prevent and report criminal offences and to protect the security, reputation and integrity of our business, for reference and evidence related to claims or litigation, etc.
  • Security and system monitoring such as, to authenticate and access controls and logs where applicable; to monitor of system, devices and internet; ensuring IT security; to prevent and solve crimes; and risk management and fraud prevention.The Company have following legal bases to support the processing of personal data, etc.

The Company have following legal basis to support the processing of personal data.

  • To prevent harm or danger that might happen to a person both physically and mentally.
  • To act in compliance with the contract which have the Company and data subject as the contractors, or to process a request by data subject prior to the contract.
  • To act for the legitimate benefits of the data controller or other parties that is not the data controller. o For data controller to act in compliance with the law.
  • The usage, collection or disclosure of personal data is consented by the data subject.

5. Transfer of your Personal Data to other parties or other countries (if any)

The Company realizes the importance of ensuring that your personal data are well protected, the Company will try to limit the access to personal data for only the personnel that need it to fulfill their tasks. Employees or personnel of the Company, including external parties that are in contractual obligation related to indicated personal data processing with the company or vendors that act in the name of the Company shall be the receiver and processor of your personal data. The Company will only disclose and share the data with data processor that provide service to the Company and agree to protect your personal data from usage, access or disclosure without permission. As for additional information about personal data that will be disclosed by the Company, you can contact the Company’s DPO.

The Company might provide your personal data to other companies or sectors to complete the company’s business or joint-business, travelling, co-hosting, profession affiliations and research. The Company might also disclose your personal data to the authorities that manage the immigration, taxation, national security or crime as indicated by the law.

The Company might transfer your personal data to overseas to accomplish the Company’s business objective. You shall give consent to data transfer to overseas by the Company to a person or company in other country which is under the jurisdiction of corresponding country’s law, in which the personal data protection law of said country is of the same level and not of the same level as Thailand’s PDPA. However, the Company will take utmost appropriate action to protect your personal data in compliance with Thailand’s PDPA.

6. Personal Data Retention Period

The Company’s shall only store your personal information as the indicated retention period which is necessary to fulfill the Company’s goal, or as indicated by the law. The Company shall have a system or standard to remove or delete the personal data which is no longer necessary to store, use, process or disclose. However, in case of protecting the Company’s legitimate interest or to act in compliance with the Company’s policy, the Company reserves the right to extend the data retention period to the appropriate period in compliance with the law.

7. Your Rights

Subject to the applicable data protection laws in Thailand, you may have a number of rights regarding the collection, use, disclosure and/or transfer of your Personal Data, including:

  • Right to withdraw your consent: where you have given your consent for the collection, use, or disclosure of personal data, you have the right to withdraw your consent at any time,
  • Right to access: you can access and obtain a copy of information relating to the collection, use, disclosure and/or transfer of your personal data, and a copy of your personal data, or request that we disclose the acquisition of your personal data without your consent,
  • Right to data portability: where legally applicable, you have the right to request us to provide your personal data in a structure, commonly used and machine-readable format using tools or devices which function automatically and by which personal data can be used and disclosed in automatic mode, and transmit or transfer your personal data in such format to another organization,
  • Right to object: You have the right to object to the collection, use, or disclosure of your personal data including for direct marketing purposes in any case, which covers profiling related to such direct marketing;
  • Right to erase or destroy: you can request the deletion, destruction, or anonymization of your personal data to the extent permitted by law,
  • Right to restrict: you can request the restriction of the use of your personal data, for example in the case you found that your personal data is inaccurate, you can request to restrict the use of such data until it is modified,
  • Right to rectify: where you consider that your personal data is inaccurate, not up-to-date, or incomplete, you can require that such Personal Data be modified accordingly,
  • Right to lodge complaints in case you notice that we do not comply with the data protection laws: you are entitled to lodge a complaint with the competent authority regarding the collection, use, and/or disclosure of your personal data by us or on our behalf.

However, your exercising of rights may be limited by the applicable laws, including the Company’s privacy policy and other regulations as indicated by the Company. There may be certain cases where we can reasonably and lawfully decline your request, for example, due to our legal obligation or court order. To exercise your rights, you must submit a written request to the Company’s DPO with details as indicated in the article 10.

8. Data Security Measure

The Company is employing security systems that are up to the standard both technologically and process-wise to protect data that is under the management of the Company from usage that causes damages, abuse or editing by the Company’s contractors. The Company will also protect your personal data from data loss, and access, usage, or disclosure without authorization or permission. The Company will only give access to the data to the responsible person or personnel that must access the data and will do the best of its ability to prevent damages, abuse, or editing of your personal data.

9. Personal Data Breach Report

You can report about incident or action which might be considered as violation of personal data to the DPO with contact details indicated in the article 10 of this notice. To maintain the security of your personal data and reduce any damages that might be caused from said violation, the Company would like your cooperation in reporting about the incident that you found immediately or as soon as it is possible.

10. Contact us

If you have any questions, comments, or concerns about our privacy practices or, if you would like to submit a request based on a right listed in this Notice, please contact us at the appropriate address below.

Corporate Quality Management (CQM)
transcosmos (Thailand) Co., Ltd. Pakin Building 8th. Floor, 9
Ratchadaphisek Rd, Din Daeng, Bangkok 10400
Tel: 02-021-5503, Internal: 16602 Email: dpo@trans-cosmos.co.th

Last updated: 06 Mar 2024