This Notice applies to applicants seeking vacancies in Myanmar. 

Introduction 

DKSH Holding Ltd and its affiliated company take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information relating to you ("Personal Data") will be treated in a secure and confidential manner as set out in this Privacy Notice ("Notice"). 

1. Data Controller / List of Controllers 

The Data Controller of your Personal Data is the company of the DKSH Group that has posted the specific vacancy for which your application is suited.   

In particular, depending on the company of the DKSH Group that has activated a specific position, the Data Controller may be one of the companies listed hereunder: link

In case of a spontaneous application, the Data Controller is DKSH Holding Ltd. with its registered office at Wiesenstrasse 8, P.O. Box 888, 8034 Zürich, Switzerland.  

For any questions or if you wish to exercise any of your rights regarding the processing of your Personal Data, you may contact DKSH Holding Ltd at dataprotection@dksh.com or the DKSH company acting as the Data Controller, at the contact details available at the following link. 

2. Personal Data We Collect 

We may collect and process various types of Personal Data about you for the purposes described in this Notice, including: 

• Data about you: forename and surname, gender, nationality, civil/marital status, date of birth, age, home contact details (e.g., address, telephone number, e-mail), emergency contact details (name and telephone number) national ID number, immigration and eligibility to work data, next-of-kin/dependent contact information, heath records.   

• Data about your employment history and qualifications: qualifications, references 

• Data about your application: CV and application, interview data, audio and video recordings of interviews, as applicable, verification of references  

• as applicable, legal and criminal records data, in compliance with the applicable laws and in specific circumstances (e.g., for candidates for positions in the Finance Department)  

3. How We Collect Your Data 

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or at interviews.  

We may also receive or obtain Personal Data about you from third parties; for example, recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers (such as companies that benchmark professional careers); background check providers; search information providers; and reference agencies (such as companies that provide credit scores), as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying.  We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law). 

We may also receive information which may include your Personal Data from our hiring manager, from Human Resources, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

4. Why We Process Your Personal Data and Legal Basis for Processing 

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with DKSH. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to enter into an employment agreement with you. In some cases, it may mean that we are unable to continue with your application for employment as DKSH will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process. 

We collect the Personal Data described in Section 2 above for the purposes of managing DKSH’s recruitment related activities. DKSH may also use your Personal Data in relation to the evaluation and selection of applicants, including for example setting up and conducting interviews and tests, and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers.  

We process your Personal Data for the purposes described above on at least one of the following legal bases: 

• the processing is necessary for compliance with a legal obligation to which DKSH is subject (notably verifying eligibility for employment or complying with obligations regarding non-discrimination, if any); or 

• the processing is necessary in order to take steps at your request prior to entering into an employment contract with you (notably verifying your qualifications and work history); or  

• the processing is necessary for the legitimate interests pursued by DKSH in hiring qualified and appropriate persons (notably by conducting interviews), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data. 

The processing of legal or criminal records data will be undertaken in compliance with applicable laws and in specific circumstances (e.g., for candidates for positions in the Finance Department), where required or permitted by the applicable laws, national collecting bargaining agreements or binding resolutions of the relevant Data Protection Authority. The legal basis for such processing will be necessity for compliance with a legal obligation, and/ or DKSH’s legitimate interests in hiring, for roles involving the regular handling of significant assets, persons who have proven their reliability and probity and/or your explicit consent, as applicable and required by local laws. 

If You provide us with Personal Data of other individuals (e.g., emergency contacts), You confirm that you have obtained their consent to share their information with us for the purpose outlined in this Notice.  

5. With Whom Do We Share Your Personal Data? 

As a global organization consisting of businesses in various countries, DKSH may hire for its sites, and use resources, located throughout the world. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so. Within DKSH, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance). 

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely recruiters; companies (notably SuccessFactors) that host, support and/or maintain the IT systems or applications supporting our recruitment and other HR systems; and companies that verify your references, undertake background checks or conduct vetting on our behalf. 

If your application for employment with DKSH is successful and you accept a job offer from us, your Personal Data may also be shared with HR information, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors.  

DKSH expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security. Where these third parties act as a "data processor" (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

DKSH will not disclose your Personal Data to unauthorized third parties.  

6. Data Transfers Outside your country 

From time to time your Personal Data will be transferred outside your country for the purposes described in this Notice. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your details and the provision of support services. 

We may share your Personal Data (i) with colleagues within DKSH; (ii) with colleagues within the DKSH Group (both in the country where you are applying for a position, and in other countries in which the group has operations (including countries outside your country); and (iii) with third parties as described in this Notice.   

We will provide you upon your request a list of the countries located outside your country to which your Personal Data may be transferred, and an indication of whether they have been determined  to grant adequate protection to Personal Data. Please send your request as indicated in How to Exercise Your Rights below.  

In case of transfers outside your country, we will ensure appropriate safeguards, such as  Standard Contractual Clauses, Binding Corporate Rules, or other legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer. Please send your request as indicated in How to Exercise Your Rights below. 

Transfers of Personal Data are based on the same legal basis as applicable for the respective purposes of processing as set forth in Section 4 above.  

7. Data Retention 

Our general approach is to retain candidate Personal Data for one year from completion of the last vacancy you applied for, to the extent you were a suitable candidate for the vacancy, so that we may consider you for future job openings, unless you expressly object. In all cases, we will retain your Personal Data for exercising or defending legal claims, for a period of time corresponding to the applicable statute of limitations, or legal or regulatory obligations. 

If you accept employment with DKSH, your Personal Data will be held on the basis set out in our Employee Privacy Notice, which is provided to all employees and that you will be required to acknowledge that you have read. 

8. Your Rights 

• Right to Access - you have the right to request access to any of your Personal Data that DKSH may hold, and to obtain information about the processing of that data.    

• Right to Correct - DKSH will take steps in accordance with applicable legislation to keep your Personal Data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). You also have a responsibility to ensure that changes in personal circumstances are notified to DKSH so that we can ensure that your Personal Data is up-to-date. 

• Right to Withdraw Consent - in the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.  

• Data Portability - where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to DKSH in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible. 

• Right to Erasure - you are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where Personal Data is unlawfully processed. 

• Right to Restriction of Processing - you have the right to restrict our processing of your Personal Data (that is, allow only its storage) where:  

• you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;  

• the processing is unlawful but you do not want us to erase the Personal Data; 

• we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defence of legal claims; or  

• you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether DKSH has compelling legitimate grounds to continue processing. 

• Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defence of legal claims. 

• Right to Object to Processing Justified on Legitimate Interest Grounds - where we are relying upon our legitimate interests to process Personal Data, you have the right to object to that processing.  If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis. 

• You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.   

9. How to Exercise Your Rights  

To obtain further information regarding your rights, to exercise any of your rights, or to ask any questions regarding the processing of your Personal Data, please contact dataprotection@dksh.com or DKSH company acting as the Data Controller, at the contact details available at the following link. 

10. Changes to This Notice 

Any changes or updates we may make to this Notice will be posted on this page in advance, if applicable.  If we still have your email on file, as described in Section 7 above, we will notify you in advance of any changes to this Notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice. 

11. Acknowledgement  

By submitting my application, I declare to have read, understood, and agree to process my personal data as per this Notice.