It is the policy of Leadsourcing to respect the confidentiality of personal data and the privacy of individuals. Leadsourcing is bound by the Personal Data (Privacy) Ordinance (Cap. 486) and its amendment Ordinance of the laws of the Hong Kong Special Administrative Region.
We are committed to being open and transparent about how we manage personal information.
Types of personal data held by Leadsourcing 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:
- IC number
- Photo page of passport
- Visa details
- Date of birth
- Contact details
- Emergency contact details
- Work telephone number
- Work email address
- Work experience
- 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 Leadsourcing
- 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 Leadsourcing 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 leadsourcing.co 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
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 Leadsourcing’ 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 Leadsourcing
- The intended use of personal data by Leadsourcing and the promotion of [Leadsourcing recruitment services] is consistent with and covered by the consent of the third party
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 Leadsourcing
- Leadsourcing employees and potential employers located in Hong Kong (and any other countries where Leadsourcing may provide its services in the future) regarding possible work placements or to assist us in providing our services to you
- 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 Worker’s 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 Leadsourcing’ website.
Management of personal data
At Leadsourcing, we train our staff to respect the confidentiality of customer information and the privacy of individuals. Leadsourcing regard breaches of your privacy very 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?
Leadsourcing 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.
Enquiries & complaints
You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches to, or otherwise contact us:
Address: Unit B, 12/F, Hang Seng Causeway Bay Building, 28 Yee Wo Street, Causeway Bay, Hong Kong
We aim to acknowledge receipt of all complaints within 10 working days and aim to resolve all complaints within 40 days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time.
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
- if the data has been disclosed to a third party during the 12 months immediately preceding the day on which the correction is made; and Leadsourcing has no reason to believe that the third party has ceased using the data for the purpose (including any directly related purpose) for which the data was disclosed to the third party, take all practicable steps to supply the third party with a copy of the data as so corrected accompanied by a notice in writing stating the reasons for the correction.
- If we refuse to correct your personal data in accordance with the Personal Data (Privacy) Ordinance, we will notify you in writing of the reasons detailing our refusal to correct the information and the process for escalation regarding this refusal. If you wish to exercise your rights of correction you should contact us. We will not charge you for making the request to correct your information.
Leadsourcing will receive feedback via emails. Any feedback that is sent becomes the property of Leadsourcing. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or, with your consent, contact you for further feedback on the site.