PRIVACY NOTICE FOR APPLICANTS, EMPLOYEES, DIRECTORS AND
CANDIDATES INCLUDING THEIR ASSOCIATED PARTIES

 

Protecting your privacy and the confidentiality of your Personal Data is fundamental to the way ANZ Bank (Thai) Public Company Limited does business.

The purpose of this Privacy Notice (“Notice”) is to make you aware of how we will collect, use, and/or disclose your Personal Data (i.e. information which identifies you) and the measures and processes we have put in place in order to ensure that we comply with the Personal Data Protection Act, B.E. 2562 (A.D. 2019) (“Thai PDPA”).

1. SCOPE
This Notice is given by ANZ Bank (Thai) Public Company Limited (“ANZ Thai”, “we” or “us”, “our”) to you (applicants for an employment or contract position, referees, potential candidates we have contacted, candidates, employees and the board of directors of ANZ Thai) (collectively referred to as “you” or “your”). We act as a Controller for the Personal Data we collect about you or during our dealings with you, and where applicable, about your associated parties such as your spouse, de facto partner and children (your “Personal Data”). This means that we determine the purposes for and the way we or our Processors process your Personal Data.

If you provide ANZ Thai with Personal Data about you or, where applicable, about your associated parties or if you direct someone else to give their Personal Data to ANZ Thai, you must show that person a copy of this Notice and ensure that you shall deliver the consent form executed lawfully from such person to us so that they can understand the way their Personal Data may be collected, used and/or disclosed.

The terms ‘Controller’, ‘Data Subject’, ‘Processor’ and ‘Personal Data’ are as defined in the Thai PDPA. Personal Data refers to information of natural persons residing in the Kingdom of Thailand which enables the identification of such person, directly or indirectly.

2. WHAT THIS NOTICE COVERS

2.1 This Notice covers:
a) What Personal Data we collect about you;
b) How we obtain your Personal Data;
c) Fair and lawful processing;
d) Recording communications with you;
e) International Transfers of your Personal Data;
f) When we may disclose your Personal Data;
g) Protecting your Personal Data;
h) Your rights in relation to the Personal Data we collect;
i) How long we will hold your Personal Data for;
j) How we update or change this Notice; and
k) How you can contact us.

3. WHAT PERSONAL DATA WE COLLECT AND HOLD ABOUT YOU

3.1 We may collect, hold and process the following types of Personal Data about you, or where applicable, about your associated parties (as is appropriate from time to time):
a) First and last name, middle name, email address, home address and other contact details;
b) Date of birth;
c) Place of work;
d) Place of birth and nationality;
e) Identification documentation, such as copy of the passport, driving licence, ID card or such other documentation as is required by local law. Copies of these documents may include a photograph of your face and shoulders;
f) Transaction and account information;
g) Your resume, work history and references from your previous employer (s);
h) Information about your current level of remuneration, including any benefit entitlements;
i) Details of your professional activities and interests;
j) Details of your education, qualifications and references from your institutions of study;
k) Your interests and extra-curricular activities;
l) Information from any interviews, tests or assessments;
m) Information you have publicly shared on professional networks (such as LinkedIn) or other social media which may be accessed by prospective employers in accordance with applicable privacy laws; and
n) Other information needed to evaluate your suitability for a position including information which you provide to ANZ Thai.

3.2 We may collect and process Personal Data (as set out above) that could include “sensitive data”. This is personal data pertaining to racial or ethnic origin, criminal records, health data, disability, genetic data, biometric data, data concerning sexual behaviour as indicated in the Thai PDPA or other sensitive data as may be announced by the Personal Data Protection Commission, which may affect the data subject in the same way (collectively referred to as “Sensitive Data”). However, we will collect the Sensitive Data only as we indicate in paragraph 3.1 of this Notice. We will only process your Sensitive Data where it is necessary for reasons of data required for onboarding process of new employees (such as identification documents which may contain sensitive data or medical records), or in case existing employees, directors and/or their associated parties have a new dependent, or in case of substantial public interest, such as anti-money laundering. We have suitable and specific measures in place to safeguard the fundamental rights and the interests of the Data Subject and if there is any change to the collection or processing of any Sensitive Data that we may collect or process in relation to you, we will obtain your express consent.

3.3 In certain circumstances, it would be necessary for you to provide us with your Personal Data for the following reasons:

  • to enable us to provide services to you or to comply with our legal obligations;
  • to create a job applicant account and candidate profile;
  • to perform a contract to which you are party, or in order to take steps at your request prior to entering into such contract;

In case of the Sensitive Data, for the following reasons:

  • For onboarding process of new employees (such as identification documents which may contain Sensitive Data or medical records);
  • In case of substantial public interest, such as anti-money laundering;
  • In case that we need to disclose your Sensitive Data to the third Parties who process your Personal Data on our behalf or as instructed by companies of the ANZ group (such as our systems providers) or the third parties who process your Personal Data on their own behalf but through providing us or you with a service on our behalf (such as our agents, contractors, professional advisers, service providers that we engage to carry out or assist with our functions and activities including participants in payment systems and credit reference agencies);
  • In case that you or your associated parties have a new dependent;

In other circumstances, it will be at your discretion whether you provide us with Personal Data or not. However, failure to supply any of the Personal Data we may request may mean that we are unable to create a job applicant account and candidate profile for you on our careers website. Our careers website is maintained under an agreement between Australian and New Zealand Banking Group Ltd ABN 11 005 357 522, of Level 9, 833 Collins Street, Docklands, Victoria, Australia 3088 (“ANZ”) and its external service providers. The website facilitates our candidate application process by collecting and passing the Personal Data you provide through this website to ANZ, members of the ANZ group of companies and third parties who assist in the evaluation of candidates.

In the context of recruitment activities, for detailed information please refer to the privacy statements for each relevant country as published on our ANZ Banking Group Limited website https://anzbankingd.valhalla10.stage.jobs2web.com/content/Global-Privacy-Statement/?locale=en_GB. Your Personal Data will only be processed to the extent that it is necessary for the specific purposes notified to you.

3.4 We make every effort to maintain the accuracy and completeness of your Personal Data which we store and to ensure all of your Personal Data is up to date. However, you can assist us with this by promptly contacting us if there are any changes to your Personal Data or if you become aware that we have Personal Data relating to your associated parties which is inaccurate (see paragraph10 below). We shall not be responsible for any losses you suffer arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.

4. HOW WE OBTAIN PERSONAL DATA

4.1 We collect your Personal Data from the information you provide when we consider and process your request for, provide, manage or administer and any additional information provided by you or others during the course of recruitment and employment including:
a) when you provide your personal information via application forms, resumes and covering letters, update your profile through our ANZ Banking Group careers website, speak via telephone or use video recorded interviews etc.; and
b) from third parties, for example your previous or current employers, to verify details about you and/or your application to work for us; and
c) in various other ways you interact with us during the recruitment and onboarding process.

4.2 If you are a candidate, an employee or a director, we will also collect information about you that is publicly available, including information from the electoral roll or other websites. We sometimes collect information about you from additional online and offline sources including social media (to the extent you choose to make your personal information public) and commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Notice.

5. FAIR AND LAWFUL COLLECTION AND PROCESSING

5.1 We will only collect and process your Personal Data where:
a) the collection and processing is necessary to comply with our legal obligations including:
     (i) to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes;
     (ii) to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies; and
     (iii) to comply with court orders and exercise and/or defend our legal rights, as otherwise permitted, or required by any applicable law or regulation; or the processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into such contract; or
b) the collection and processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into such contract; or
c) the collection and processing is necessary for our legitimate interests or the legitimate interests of others (except where such interests are overridden by the interests or rights of you and your associated parties requiring the protection of their Personal Data) including:
     (i) for monitoring and assessing compliance with ANZ Thai’s policies and standards;
     (ii) to comply with court orders and exercise and/or defend our legal rights, as otherwise permitted or required by any applicable law or regulation;
     (iii) for administrative purposes in relation to the security and access of our systems, offices, platforms and secure websites and applications;
     (iv) for any other legitimate business purpose including the reasons set out in section 8 below; or
d) you confirm and shall provide the adequate evidence that your associated parties consent to the processing of their Personal Data on the basis set out in this Notice including in relation to the processing of any Sensitive Data collected by us;
e) necessary for the performance of your application process and to determine whether to enter into an employment contract with you;
f) any other circumstances where you have given us your consent.

6. RECORDING COMMUNICATIONS

6.1 We and persons acting on our behalf may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, instant messaging, chat rooms, fax and other electronic communications) between you and our employees, agents, consultants, contractors or other personnel and non- ANZ Thai personnel/ individuals -. We only do this to the extent permitted by applicable law for legitimate business purposes or other purposes permitted or required by law. We collect this type of Personal Data for several reasons including but not limited to:
a) recording fact;
b) complying with applicable law and regulation;
c) complying with internal procedures and policies;
d) facilitating administration and support;
e) assisting with security, crime prevention and fraud purposes; and
f) investigating or detecting unauthorised use, wrongful use or abuse of our services, systems or other material

7. DOMESTIC AND INTERNATIONAL TRANSFERS OF PERSONAL DATA

7.1 Your Personal Data may be transferred to and processed by third party service providers and/or entities within the ANZ group of companies, whether such companies are located within or outside the Kingdom of Thailand, other than the entity that collected the Personal Data. We will only disclose your information to such third party service providers only to the extent necessary for the service they provide to us.

7.2 Where local regulations permit, your Personal Data will be processed in (including accessed in or stored in) for the purposes set out in paragraph 5 above a country or territory outside the Kingdom of Thailand, which may offer the same level of protection of Personal Data. By providing your Personal Data to us, you agree to this processing. We will ensure that we have adequate safeguards in place so that your Personal Data is treated securely and in accordance with applicable law and regulation and with our policies and standards. If you would like a copy of the safeguards we have put in place, please write to us at the address set out in paragraph 13 below.

7.3 The most common reason for us disclosing information overseas is because we use service providers to perform some functions on our behalf, and some of these service providers are located outside the Kingdom of Thailand. We only disclose your information to these organisations when it is necessary for the services they provide to us. For the most part, these service providers are entities related to us which perform a range of technology, operational and customer service functions for us. These entities are in the following countries: Australia, China, Fiji, India, New Zealand and the Philippines. In some countries, the law might compel us to share certain Personal Data, e.g., with tax authorities or National Bank. Even in these cases, we will only share the Personal Data with people who have the right to see it.

7.4 ANZ may also use other overseas service providers to help with our recruitment or candidate sourcing. For example, certain positions require psychometric assessment and ANZ may use a third party to complete the task with your consent. ANZ uses external service providers based in the USA, Asia, and Europe to help us manage your application and we will therefore need to send your Personal Data to an administrator with processing and/or data storage facilities in these locations.

7.5 The above is not a complete list of the countries to which your information may be disclosed when applying for a role. It may require ANZ to disclose your Personal Data overseas and the countries to which we may disclose your information will depend on the circumstances but will still relate to the purpose of assessing your application.

7.6 When doing so we will comply with applicable personal data requirements and take appropriate safeguards to ensure the security and integrity of your Personal Data.

8. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA

We do not and will not sell, rent or trade your Personal Data. We will only disclose your Personal Data in the ways set out in this Notice and in the following circumstances:
a) to any entity within the ANZ group of companies;
b) to third parties who process your Personal Data on our behalf or as instructed by ANZ group of companies (such as our systems providers);
c) to third parties who process your Personal Data on their own behalf but through providing us or you with a service on our behalf (such as our agents, contractors, professional advisers, service providers that we engage to carry out or assist with our functions and activities including participants in payment systems and credit reference agencies);
d) to any provider of a guarantee, security or other credit support for obligations to us;
e) to financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
f) to any third party to whom we assign or novate any of our rights or obligations;
g) to any prospective buyer in the event we sell any part of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your Personal Data could form part of one of the assets we sell; and
h) to any government, regulatory agency, enforcement or exchange body or court where we reasonably believe that we are required to do so by applicable law or regulation or by any court or tribunal order or at their request where it is legal to do so.

9. ANZ THAI PROTECTS YOUR INFORMATION

9.1 ANZ Thai protects your Personal Data from misuse and loss. We also protect it from unauthorised access, modification and disclosure by ensuring that your Personal Data can only be accessed by people properly authorized to have access. ANZ Thai may store your Personal Data in hardcopy documents or electronically. ANZ Thai maintains physical security, such as locks and security systems, over our paper and electronic data stores and premises. ANZ Thai also maintains computer and network security. For example, ANZ uses firewalls (security measures for the internet) and other security measures such as identification codes and passwords to control access to computer systems. ANZ Thai continually maintains and monitors its online security systems to ensure that ANZ Thai’s online services are secure and that your Personal Data is appropriately protected when you use these services.

10. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT

10.1 Your rights in relation to the Personal Data are as follows:

  • Right to Withdraw: This enables you to withdraw your consent to our collection, usages, processing and disclosure of your Personal Data, which you can do at any time. We may continue to collect, use, process and disclose your Personal Data if we have another legitimate reason to do so;
  • Right to Access: This enables you to receive a copy of Personal Data we hold about you and to check that we are lawfully collecting, using, processing and disclosing it;
  • Right to Correct: This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • Right to Erasure: This enables you to ask us to delete or remove, destroy or anonymize your Personal Data where there is no good reason for us to continue collect, use, processing or disclose it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below);
  • Right to Object: This enables you to object to the collection, usages, processing and disclosure of your Personal Data where we are relying on the legitimate interest and there is something about your particular situation which makes you want to object to the processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes and profiling activities;
  • Right to Restrict Processing: This enables you to ask us to suspend the processing of your Personal Data, for example, if you want us to establish its accuracy or the reason for processing it;
  • Right to Portability: Request the transfer of your Personal Data in machine readable formats to another party; and
  • Right to Lodge a Complaint: This enables you to file the complaint with a related government authority, including but not limited to, the Thailand Personal Data Protection Committee.

10.2 If you wish to proceed with your rights regarding your Personal Data as mentioned above, receive a copy of the Personal Data collected from you, to the extent you are entitled to do so under applicable law, you can make such a request by writing to us at the address set out in paragraph 13 below. We will respond to your request within the time prescribed by applicable law.

If you wish to make the complaint about how we process your Personal Data, please contact us and we will try to consider your request as soon as possible. This does not prejudice your right to file the complaint with a government authority that has a data protection authority.

10.3 In any of the situations listed above, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data, we may request that you provide us with a copy of a valid means of identification and verification of the identity of the individual whose Personal Data is the subject of such a request.

11. HOW LONG WE WILL HOLD YOUR PERSONAL DATA FOR

We will only retain your Personal Data for as long as necessary, but such retention period shall not exceed 10 years after, to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. However, if you wish to have your Personal Data removed from our databases, you can make such a request by writing to the address set out below in paragraph 13. Subject to any legal or regulatory requirements, we will then delete your Personal Data (to the extent technically practicable).

12. HOW WE UPDATE OR CHANGE THIS NOTICE

12.1 We may change or update parts of this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by publishing the updated Notice on https://careers.anz.com/content/Global-Privacy-Statement/?locale=en_GB. If we make changes to this Privacy Policy that are related to the collection, usage, disclosure and/or transferring of your or your associated parties’ Personal Data, we will take reasonable steps to inform and obtain the consent from you and your associated parties prior to such changes.

12.2 This Notice was last updated in May 2022.

13. HOW YOU CAN CONTACT US

13.1 If you would like to contact us in relation to this Notice or anything else in connection with the Personal Data we collect about you and your associated parties, including, without limitation, where you would like to update your Personal Data, would like a copy of the data we collect on you or would like to raise a complaint or comment, please contact us using the details set out below.

13.2 In the Kingdom of Thailand:

Email: PDPAThailand@anz.com and/or Thailand.TC@anz.com or Telephone: +66 (0)2 263 9700, +66 (0) 2 263 9768

Post: The Data Protection Representative, ANZ BANK (THAI) PUBLIC COMPANY LIMITED, Level 8, Athenee Tower, 63 Wireless Road, Lumpini, Pathumwan, Bangkok, 10330, Thailand

13.3 In any other country:
Please contact your usual ANZ Thai representative, explaining that your communication is in relation to data protection.