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Talent Marketplace Platform Privacy Policy

  1. Overview
    1. The Institute of Singapore Chartered Accountants (“ISCA”) owns and operates the website https://talent.isca.org.sg/ and all its subdomains (“Site”) and provides the ISCA Talent Marketplace platform and application (“Services”).
    2. This Talent Marketplace Platform Privacy Policy applies to all Personal Data processed by ISCA in its provision of the Site and Services. For the purposes of this Talent Marketplace Platform Privacy Policy:
      1. Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which ISCA has or is likely to have access. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).
      2. process”, in relation to Personal Data, means carrying out any operation or set of operations in relation to the data, including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
    3. ISCA takes its responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the Personal Data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data, and we are committed to protecting your Personal Data. Please read this policy to understand what Personal Data is collected or processed by us, and what purposes it is used and/or disclosed for.
    4. The Site and Services may be accessed and used only by individuals who can form legally binding agreements under applicable laws, who are 18 years of age or older, and who are legally permitted to access and use the Site and Services under applicable laws.
    5. Access to and use of the Site and Services is conditional upon acceptance of ISCA’s Terms of Use accessible at https://talent.isca.org.sg/platform-terms-of-use (“Terms of Use”), into which this Talent Marketplace Platform Privacy Policy is incorporated by reference and which this Talent Marketplace Platform Privacy Policy is an integral part of. By accessing and/or using the Site or Services, you acknowledge you have read ISCA’s Terms of Use including this Talent Marketplace Platform Privacy Policy, and that you expressly agree to the Terms of Use and expressly consent to ISCA’s collection, use, disclosure, and processing of your Personal Data in accordance with this Talent Marketplace Platform Privacy Policy. If you do not agree to the Terms of Use and/or do not consent to such collection, use, disclosure and processing of your Personal Data, please do not access or use the Site and/or Services.
    6. If you provide Personal Data of another individual to us, you warrant and agree that that other individual has fully read and understood this policy and has consented to you disclosing his/her Personal Data to us for processing as described in this policy.
    7. We reserve the right to amend this Talent Marketplace Platform Privacy Policy at any time in accordance with the relevant laws and regulations.
  2. Data Collection and Use
    1. ISCA collects and uses your Personal Data to provide you with the Site and Services, and to customise and improve the Services to make your experience more secure and convenient.
    2. The types of Personal Data that ISCA may collect from you in the course of using the Site and Services include, but are not limited to:
      1. personal information such as your name and date of birth;
      2. contact information such as postal addresses, email addresses, contact numbers;
      3. employment information such as work experience, employment status, industry sector, job function and responsibilities, designation;
      4. academic qualifications such as schools attended, courses of study, period of study and academic results;
      5. professional qualifications and memberships with professional bodies, including SCAQ candidate numbers;
      6. recruitment information such as your curriculum vitae, professional resume, job preferences, salary expectations, notice period;
      7. information about your browsing session and usage of our Services that is automatically collected when you browse the Site or use the Services, such as your IP address and IP domain, operating system and platform, clickstreams, location, clicked links and viewed content (“Browsing Information”); and
      8. any Personal Data as ISCA may deem essential or appropriate from time to time to fulfil your commercial relationship with ISCA or to provide the Site or Services to you.
    3. The purposes for which ISCA may use or process your Personal Data include, but are not limited to, the following:
      1. to provide the Services requested by you;
      2. for customer service, communication and administrative purposes;
      3. to fulfil any legal requirements and relevant regulatory guidelines;
      4. to customise your online experience;
      5. to analyse and understand our customers’ behaviour and preferences;
      6. if you consent, for marketing purposes, and to inform you of certain educational courses, events, and promotions which may be of interest to you. You may modify or revoke this consent by contacting our Data Protection Officer using the contact details set out at the end of this Talent Marketplace Platform Privacy Policy;
      7. conducting due diligence and investigations, such as user authentication and checking for fraud.
    4. ISCA only collects and uses Personal Data about you that ISCA considers reasonably necessary for achieving the purposes for which such Personal Data was collected.
    5. If you have requested for any services which can only be fulfilled upon the collection, use, disclosure or processing of your Personal Data, you will be deemed to have consented to such collection, use, disclosure or processing.
    6. We may collect, use, disclose or process your Personal Data without your consent under circumstances which are permitted by the PDPA.
  3. Sharing with and Disclosure to Third Parties
    1. Certain Services require your Personal Data to be disclosed to third parties. ISCA will only disclose your Personal Data to third parties to the extent that it is necessary to enable ISCA to provide Services to you, or for purposes to which you have consented.
    2. The purposes for which ISCA may disclose your Personal Data to third parties include, but are not limited to:
      1. fulfilling your requests for Services to be provided to you, including matching job seekers with employers;
      2. customer service, communication and administrative purposes;
      3. making insurance claims;
      4. protecting, proving or enforcing our legal rights;
      5. where required for any legal proceedings; and
      6. conducting due diligence and investigations, such as user authentication and checking for fraud.
    3. Third parties to whom ISCA may disclose your Personal Data include, but are not limited to:
      1. our related entities, for the purposes stated above;
      2. our third party service providers (including data centre and cloud service providers, service providers which host, maintain, or manage the Site or our software and/or data from the Site or the Services, and other technology service providers) to enable us to provide Services to you;
      3. marketing agencies where you have consented to receive marketing materials from us;
      4. legal advisors, consultants, auditors, and any other agents or subcontractors acting on ISCA’s behalf; and/or
      5. government or regulatory authorities, whether within or outside of Singapore, to the extent required in the normal course and scope of ISCA’s business in the provision of the Site and Services, the courts where required in the course of legal proceedings, or otherwise where required by applicable law, statute, regulation or by-law, regulatory or governmental order or court order.
    4. We will take all reasonable efforts to ensure that no unnecessary disclosure of Personal Data to third parties takes place.
    5. Though ISCA strongly encourages all third parties ISCA works with to comply with the Personal Data protection requirements under the PDPA and/or other relevant laws, ISCA cannot be responsible for and hereby excludes all liability for any third party’s non-compliance with the PDPA and other relevant laws.
    6. The Services may enable you to view, connect to, and/or download third-party websites, software, services and/or materials (“Third Party Content”). If you access or use such Third Party Content, please note that these third parties have their own privacy policies and that ISCA does not accept any responsibility or liability for these policies, or any acts or omissions of such third parties. Please check these policies before you submit any information to these third parties.
    7. ISCA will disclose your Personal Data to Hired1st Global Ltd. which is ISCA’s primary service provider hosting, managing, and supporting the talent marketplace platform (“Hired1st”). The disclaimers of liability and responsibility in this Talent Marketplace Platform Privacy Policy do not apply to liability and responsibility for Personal Data processed on ISCA’s behalf and for its purposes by Hired1st to the extent that Hired1st is its data intermediary.
  4. Processing of Personal Data by Employers
    1. Users who use the Site and Services in their capacity as, or on behalf of, employers (“Employers”):
      1. must not use or process Personal Data of individuals obtained on or through the Site or Services except as reasonably necessary to assess such individuals’ suitability for the Employer’s job openings and to hire a suitable individual to fill such job openings (“Permitted Purpose”);
      2. must keep all Personal Data obtained on or through the Site or Services confidential and must not disclose any of it to third parties; and
      3. must not copy, extract, or store Personal Data of individuals obtained on or through the Site or Services outside ISCA’s Site and Services or for the Employer’s own purposes other than the Permitted Purpose, unless it has first obtained express and valid consent from such individuals to do so.
    2. Any breach by an Employer of Section 4.1 will entitle ISCA to suspend or terminate the Employer’s right to use the Site and Services and to take legal action against such Employer.
    3. Where an Employer processes an individual’s Personal Data for the Employer’s own purposes (and this will be deemed to be the case if the Employer copies, extracts, or stores the individual’s Personal Data outside ISCA’s Site and Services), including the Permitted Purpose, ISCA will not be responsible or liable for such Employer’s processing of the Personal Data or any third-party processing that occurs as a consequence.
    4. Users must be aware that Personal Data that they make available on and through the Site and Services will be accessible to other users and ISCA cannot guarantee that such other users will not misuse that Personal Data or will comply with applicable laws. ISCA therefore encourages users to be careful about the Personal Data that they disclose and to maintain the security of their Accounts as set out in the Terms of Use. ISCA hereby excludes all liability for any user’s breach of this Talent Marketplace Platform Privacy Policy and/or non-compliance with the PDPA and other relevant laws.
  5. Security
    1. ISCA puts in place and requires Hired1st to put in place reasonable security arrangements to protect your Personal Data, in such manner and to such extent as ISCA deems reasonably appropriate to prevent unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar risks.  However, there is no such thing as "perfect security" and ISCA does not guarantee in any way, and you should not expect, that your Personal Data or private communications will always remain private and/or safe from any unauthorised access or misuse by third parties.
    2. Your Personal Data to be used by ISCA is stored on ISCA's and/or its data centre providers’ and cloud service providers’ and other service providers’ servers located in Singapore and Australia. ISCA uses and requires Hired1st to use such procedural and technical safeguards as ISCA deems reasonably necessary to protect your Personal Data against loss, theft and unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, or similar risks. Such safeguards include but are not limited to the use of encryption and firewalls.
    3. ISCA’s employees are bound by strict confidentiality obligations, and are required, as a condition of their employment, to treat Personal Data held by ISCA as confidential, and to maintain the confidentiality of that Personal Data.
    4. ISCA does not represent or warrant that there will not be, and hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar actions with regard to any data held or maintained by ISCA.
  6. Cookies
    1. ISCA or Hired1st may use data collection devices such as "cookies" on certain pages of the Site to improve your experience using the Site, promote trust and security, help analyse the web page flow and measure promotional effectiveness. The following cookies may be used:
      1. Functional cookies. These are used to remember the selections you make on our Site so that your selections are saved for your next visits;
      2. Analytical cookies. These allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
      3. Targeting cookies. These collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and
      4. Third-Party cookies. These are created by a website other than ours. We may use third-party cookies to ascertain your preferences and tailor advertisements around your interests.
    2. If you engage in activities or transactions on the Site which cannot take place without cookies that collect, use, disclose or process Personal Data, you are deemed to have consented to such collection, use, disclosure or processing if you had voluntarily provided the Personal Data for that activity or transaction, and it is reasonable that you would do so.
    3. When you first access the Site, you will be provided with options to indicate your consent to our use of cookies. Your choices will be remembered and thereafter, if you do not wish to consent to any use of cookies, please adjust your browser settings accordingly. Most Internet browsers provide you with the option of adjusting your browser security settings to disallow the use of cookies. However, please note that disabling cookies entirely may decrease the quality of your user experience.
  7. Transfer of Personal Data Overseas
    1. The Hired1st talent platform is hosted in Australia and therefore any Personal Data you provide through the Site or Services may be transferred to that country. ISCA contractually requires Hired1st to provide to all transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.
    2. If there is a need to transfer your Personal Data out of Singapore, ISCA will ensure that the overseas recipient is legally bound to provide a standard of protection to your Personal Data at least comparable to that under the PDPA, and to comply with the requirements of the PDPA in relation to such transfer. 
  8. Retention of Personal Data
    1. We will put in place measures to ensure that your Personal Data in processed through the Site and/or Services is destroyed and/or anonymized as soon as it is reasonable to assume that (a) the purpose for which that Personal Data was collected is no longer being served by its retention; and (b) retention is no longer necessary for any other legal or business purposes. 
  9. Accessing and Updating your Data
    1. If you wish to access, update or otherwise change or remove any Personal Data that you provide for ISCA’s use, or you would like to understand how ISCA has used or disclosed your Personal Data, (each a “Data Access Request”) please contact our Data Protection Officer using the contact details set out at the end of this Talent Marketplace Platform Privacy Policy. However, if you remove any Personal Data which is necessary for ISCA to provide you with the Site or Services, ISCA’s provision of the Site or Services to you may become impossible, impeded or deficient.
    2. Please note that the above right to access, update, change or remove does not apply to any data which is not Personal Data.
    3. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your Data Access Request. We reserve the right to charge a reasonable fee for the processing of any Data Access Request.
  10. Changes to the Talent Marketplace Platform Privacy Policy
    1. ISCA reserves the right to amend this Talent Marketplace Platform Privacy Policy at any time and will post any such amendments on the Site. Any amendments will apply and take effect seven (7) days after the date they are published on the Site.
    2. Please ensure that you read and accept all such amendments, and do not access or use the Site or Services if you do not agree to any amendment.
  11. Governing Law
    1. This Talent Marketplace Platform Privacy Policy will be governed by and construed in accordance with Singapore law.
    2. Any dispute, controversy  or claim arising out of or in connection with this Talent Marketplace Platform Privacy Policy, including any question regarding its existence, validity, breach or termination, shall be referred to and finally resolved by arbitration in Singapore at the Singapore International Arbitration Centre ("SIAC") or at such other venue in Singapore as the Parties may agree in writing in accordance with the Arbitration Rules of the SIAC (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this section. The seat of arbitration shall be Singapore. The arbitral tribunal shall consist of a single arbitrator to be appointed by the President of the Court of Arbitration of SIAC in accordance with the SIAC Rules. The decision of the tribunal shall be final and binding on both you and us. The language of the arbitration shall be English. The Parties hereto undertake to keep the arbitration proceedings and all information, pleadings, documents, evidence and all matters relating thereto confidential.
  12. Contact ISCA
    1. If you have further questions about this Talent Marketplace Platform Privacy Policy or wish to contact ISCA regarding ISCA’s privacy practices and policies, please contact ISCA’s Data Protection Officer at:

      The Data Protection Officer
      Institute of Singapore Chartered Accountants
      60 Cecil St 
      ISCA House
      Singapore 049709
      Email : dpo@isca.org.sg

 

Version 1 effective as of 3rd July 2025

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