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Candidates Privacy Notice

S Hotels and Resorts Public Company Limited

Employee and Candidate Privacy Notice

Last Updated : February 2021

  1. About Us
  2. Personal Data Collections
  3. Purposes of Personal Data Collection, Use, or Disclosure
  4. Cross Boarder Transfer of Personal Data
  5. Details of Personal Data Disclosure
  6. Data Subject Rights
  7. Security Measures for Personal Data
  8. Personal Data Retention
  9. Accuracy of Your Personal Data
  10. Your Responsibility Regarding Personal Data Protection
  11. Contact Us

1. About Us

[Property Name] of S Hotels and Resorts Public Company Limited and S Hotels and Resorts Public Company Limited hold a status of an employer and as a data controller according to The Personal Data Protection Act B.E. 2562 (2019) of Thailand. SHR will ensure the privacy of personal data and protect your personal data that is collected during the recruitment and employment process, and during employment period.

This Employee and Candidate Privacy Notice aims to provide information regarding collection, use, or disclosure of your personal data internationally, your privacy rights, as well as your legal protection.

SHR reserves the right to revise and updates this Privacy Notice at any time. If there is any adjustments made, it will be announced on SHR’s intranet at [SHR intranet link]

In this Privacy Notice;

“SHR” means S Hotels and Resorts Public Company Limited and [Property Name]

“Properties” means hotels, resorts, amenities, and retail spaces which we own and operate, including
but not limited to;

  • CROSSROADS Maldives
  • Hard Rock Hotel Maldives
  • SAii Lagoon Maldives
  • Santiburi Koh Samui
  • nābor koh samui bophut
  • SAii Laguna Phuket
  • SAii Phi Phi Island Village

“You” means SHR candidates, permanent employees, probationary employees, and contract employees; including those who is currently holding, held such status in the past, or has already retired.

“Thai PDPA” means The Personal Data Protection Act B.E. 2562 (2019) of Thailand.

“GDPR” means The General Data Protection Regulation (EU) 2016/679 of European Union.

“Notice” means S Hotels and Resorts Public Company Limited Employee and Candidate Privacy Notice.

“Data Subject” means any individual person who can be identified by a data; eithter by direct or indirect means.

“Data Controller” means a person or juristic person that have authority and responsibility to make decisions regarding the collection, use, or disclosure of personal data.

“Data Processor” means a person or juristic person who operates in relation to the collection, use, or disclosure of the personal data pursuant to the orders given by or on behalf of a data controller.

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2. Personal Data Collections

SHR collects your personal data only as necessary according to lawful purposes. SHR may receive your personal either directly or indirectly from the following sources;

  • Job application information such as profile data from online or other sources (such as job search websites, recruitment agencies, franchise companies, and etc.);
  • Data obtained from discussions session during the recruitment process;
  • Data from identification documents such as copy of national ID cards, passport, household registration, and driver license;
  • Technical and usage data, such as from SHR websites and applications access;
  • Data obtained from filling out our job application during the employment process, such as benefits proposal form (salary);
  • Data obtained from your feedback during the recruitment and employment processes, such as information from interviews, meetings, assessments, as well as CCTV cameras;
  • In some scenarios, SHR may collect your personal data from third party source such as data from referrer list of your former employer and data from employment history check service provider;

Nonetheless, SHR may collects your personal data such as;

  • Identity data such as name, surname, date/month/year of birth, place of birth, gender, address, email, phone number, national ID number, bank account number, driver license number, passport number, nationality, marital status, military status, and signature;
  • Family data such name, surname, relationship, age, career/title, address, work address, and phone number of family members; including data of spouse, child, and emergency contact person;
  • Identifiable image data such as picture and video of you and/or your belongings that SHR may collect during recruitment and employment process, and during employment period. Identifiable image data include data such as image from CCTV cameras, cameras, when there is access to office buildings, retail spaces, property areas, areas under SHR’s responsibility, during events, meetings, or any seminars;
  • Sensitive data such as race, religion, health information (weight, height, blood type, disability information), and biometric data such as fingerprint model data;
  • Qualification and education data such as educational background, language proficiency, training history, and other special abilities information;
  • Employment data such as work experience, previous employer information, position, salary, duration of work experience, welfare, and other income information;
  • Professional referrer data such as name, surname, position, address, and phone number;
  • Personal property data such as vehicle plate number.

Contract details: Terms and Conditions of Your Employment

  • Details of Position, affiliation, salary, contract effective date, working days and hours information including overtime, and salary payment date;
  • Details of the agreement during your contract with SHR, in the event that SHR reserves the right to change or transfer duties for general or special tasks as assigned;
  • Details of agreements regarding operation procedures and compliances. This includes non-disclosure practice for documents or any other business information that employees have learned during or after employment term; including details of penalties;
  • Details regarding disciplinary action or termination of the contract;
  • Details of no unlawful drug use confirmation.

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3. Purposes of Personal Data Collection, Use, or Disclosure

For recruitment, employment, carrying out transactions, activities, and /or subject according your request and/or to achieve SHR objectives. SHR may collect, use your personal data as well as disclose it to business group as for necessary purposes, including but not limited to the following purposes;

  • To comply with employment contract or other contract SHR has with you;
  • To manage recruitment and employment process;
  • To operate and/or manage regarding your rights including rights to receive salary, compensation, overtime payment and other benefits such as health insurance, expense reimbursement from employee benefits, leave day, bonus, and other welfare according to employment contract;
  • To track performance in accordance with work regulations, such as recording of attendance times, compliance, and disciplinary action;
  • To record various types of leave such as sick leave, maternity leave, holiday leave, and ordination leave; in order to efficiently manage SHR human resources and to ensure your rights and the exercise of such rights under the employment contract;
  • To carry out the SHR’s legal obligation relating to employee such as to confirm the status of work permit in Thailand, to file tax with the Revenue Department of Thailand, to comply with labor and welfare protection laws, to comply with safety, occupational health, and work environment laws, and to allow you to take leave and receive wages and overtime payment as required by law;
  • To serve public interest or carry out task as assigned to SHR by government agencies;
  • To serve the SHR’s legitimate interest such as to proceed with the recruitment process (identity and contact verification, applicants rating, and suitability assessment; in order to make employment decision), and to record your performance evaluation including internal audit and administrative tasks;
  • To record/update your data (including emergency contact information), ensuring that data is accurate and current, in order to avoid any misunderstandings, and to reach out to emergency contact person;
  • To achieve internal purposes regarding human resources management such as to analyze, research, and develop activity for human resources development and training, and to improve operation and employment process;
  • To prevent your potential illegal activities or negligence of duty and to record disciplinary process for effective management or determination of disciplinary measurement when necessary;
  • To prevent, reduce risk, and maintain security for office buildings, retail spaces, property areas, and areas under SHR’s responsibility, through CCTV cameras when there is an access to an area where the CCTV cameras are installed;
  • To achieve SHR’s internal objectives or to conduct public relations for external audience through both print and the SHR social medial channels. This activity include SHR collection of picture or video from events, meetings, or any seminars held by SHR. Nonetheless, the said data will not be used for commercial purposes;
  • To provide referrals upon request for current or former employees;
  • In the event that SHR receives your explicit consent, SHR will only use your personal data for purposes you have given consent to.
  • Thai PDPA and GDPR specifies sensitive data as a special category. Hence, sensitive data requires special treatment and SHR will not collect, use, or disclose your sensitive data without your consent; unless exempted by law. If SHR collects, uses, or discloses sensitive data, it will only be for as necessary by the following purposes;
  • Collect health data, disability data, and history of drug use, fraud or criminal history; in order to consider job application, make employment decision, screen job application, and investigate and prevent fraud and criminal activity;
  • Collect Biological data such as your fingerprint model data to conduct performance tracking via checking your attendance and for office building access;
  • Collect health data for labor protection and healthcare welfare;
  • Collect ethnic and religious data to maintain and promote workplace equality via providing equal opportunities.

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4. Cross Boarder Transfer of Personal Data

Your personal data may be transferred to third party or servers which located internationally. The destination country may or may not have equal data protection standard as Thailand; however, SHR will ensure before transfer that the personal data is protected with equal and appropriate security measures in accordance with the Thai personal data protection legal requirements and standard. SHR will also ensure that the transfer of personal data is lawful and under suitable legal basis such as contractual basis, legal obligation, legitimate interest, public interest, or as you have consented to SHR. In some other countries, there may be legal requirements for SHR to disclose your personal data; such as foreign tax authority and embassy of foreign country to process work permit. SHR will ensure that personal data will only be disclosed to an authorized agencies.

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5. Details of Personal Data Disclosure

SHR will keep your personal data confidential. If there is a necessity to disclose personal data in accordance with the law, SHR will only disclose to an authorized person. Nonetheless, SHR may disclose personal data to the following parties for purposes stated within this Notice.

  • Business group and/or business partner, and SHR’s authorized representative;
  • Other individuals or external parties such as SHR’s business partners and service providers, including but not limited to party such as banks, public transportation providers, health and travel insurance companies, hospitals, fund managers, payroll vendors, tax companies, visa or work permit agencies, consulting firms, telecommunication providers, information system service providers, training agencies, and construction companies;
  • Government agencies or regulators such as Revenue Department, international tax authorities, Securities and Exchange Commission, The Stock Exchange of Thailand, Student Loan Fund, Department of Skill Development, Department of Labor Protection and Welfare, Ministry of Labor, Social Security Office, and others as required by law;
  • When SHR disclose personal data to third parties, SHR will take measures to ensure your personal data protection. For example, SHR will create confidentiality agreements, implement appropriate security measures as required by law, and assign third parties with duty of customer's personal data confidentiality protection in accordance with the contract they have with SHR.

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6. Data Subject Rights

You have the rights under Thai PDPA and GDPR as follows; and you can submit a request to exercise your rights through SHR contact channel provided under topic “11. Contact Us.” SHR will then process your request as soon as possible; however, it also depends on the volume and complexity of the request.

  • You have the right to withdraw your consent and SHR will stop the processing of your personal data as soon as possible; unless there is legal limitation of the right to withdraw consent or there is contract that benefits you;
  • You have the right to access and ask for a copy of your personal data, or to request disclosure of the acquisition of personal data obtained without your consent; unless it is when SHR must comply with the law or court order, or the request of access or to receive a copy of your personal data may impact that cause damage to the rights and freedoms of others;
  • You have the right to request correction and rectification on your personal data to ensure that the data is correct, up-to-date, complete, and does not cause any misunderstandings;
  • You have the right to receive or request SHR to send or transfer your personal data to different data controller, or to directly request the personal data that SHR discloses or transfers to other data controller; unless it is impossible to do so due of the technical circumstances;
  • You have the right to request SHR to erase, destroy, or anonymized your personal data, in the event that such personal data is no longer necessary for the purpose in which it is collected for, you have withdrew your consent or object processing of personal data for direct marketing purposes and others, there is unlawful processing, and other scenarios as required by law;
  • You have the right to restrict the processing of your personal data and SHR will stop the processing of personal data; however, the personal data shall be stored for purposes such as to establish legal claims, when personal data is under review for correctness, when processing of personal data is under reviewed for higher legitimate ground, or when you request for restriction instead of deletion of your personal dat. Nonetheless, SHR will only store personal data as necessary;
  • You have the right to object the collection, use, of disclosure of personal data for direct marketing, research purposes either in the field of science, history, or statistics; unless it is necessary for public interest, higher legitimate ground, establishment of legal claims, legal compliance, exercise of legal rights, or to defend exercise of legal rights;
  • You have the right to file a complaint to relevant government agencies, in the event that you believe SHR violates or does not comply with Thai PDPA and GDPR.

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7. Security Measures for Personal Data

SHR has taken appropriate measure to ensure physical protection and technical management, to prevent your personal data from loss, misuse, or unauthorized access, disclose, change, and deletion.

In the event that SHR assign external party for system development and maintenance, resources allocation, or any other services, SHR may sets for confidentiality and/or data processing agreement in accordance with this Notice to be made; for the benefit of securing your personal data.

SHR has set the process to manage the personal data breach incident and will notify you in accordance with the law. Nonetheless, even though there is strict security measure for personal data, there is a security limitation when it comes to transmission of data on the internet. Hence, SHR is unable to guarantee the security of your personal data disclosed on online platform

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8. Personal Data Retention

SHR will retain your personal data for as long as necessary to achieve the purpose of collection, use, or disclosure as stated in this Notice. In the event that you are not recruited, SHR will retain your personal data for 3 years from the date you apply. In the scenario that you are no longer the employee of SHR, SHR will retain your data for as long as necessary, in accordance with SHR Policy and strict legal requirements.

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9. Accuracy of Your Personal Data

In order to ensure the your personal data SHR collected is to be correctly processed under the notified purpose with completeness and current, you shall notify SHR to make correction if there are changes to your personal data. You can do so by contacting Human Capital representative or regularly update your personal data on SHR’s intranet at [SHR Intranet Link]

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10. Your Responsibility Regarding Personal Data Protection

You have the responsibility to ensure that the personal data provided to SHR is accurate, complete, and current. In the event that there are changes to your personal data, you shall notify SHR as soon as possible.

It is your responsibility to provide your personal data as part of employment contract obligation which you have with SHR, especially the activity of reporting your legal leave request and providing any other work-related information. Failure to provide SHR with your personal data may affect your exercise of legal rights.

It is necessary for you to provide SHR with certain categories of personal data such as contact data, work permit data, or your financial data such as bank account number; as it is a necessary for entering or complying with employment contract. Failure to provide such personal data may result in SHR inability to enter or comply with employment contract, as well as hindering the SHR ability to manage rights and obligation in accordance with employment contract.

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11. Contact Us

If you wish to exercise data subject rights or if you have any question or complain, you can contact SHR via the following channels;

S Hotels and Resorts Public Company Limited
Address: 123 Sun Towers Building B, 10 th Floor, Vibhavadi-Rangsit Road, Chom Phon, Chatuchak, Bangkok 10900, Thailand
Phone: +66 (0) 2058 9888
Email: dpo@shotelsresorts.com