Employee Privacy Notice

Beiersdorf (Thailand) Co., Ltd. ("we," "us," or "our") has prepared this Employee Privacy Notice ("Privacy Notice") to be provided to its job applicants, employees, outsourced workers and directors ("you" or "your") to describe how we collect, use, and/or disclose your Personal Data, including to provide information about your data protection rights that you have under applicable data protection laws.

We reserve the right to amend this Privacy Notice from time to time. We recommend that you periodically revisit or keep track of content in this Privacy Notice. We may notify you and/or obtain your consent again if there are material changes, or if we are required to do so by law.

1. Types of Personal Data we collect

In this Privacy Notice, "Personal Data" means any information relating to a person, which enables the identification of such person, whether directly or indirectly, as defined under applicable data protection laws. 

We collect your Personal Data from various channels, including (i) directly from you during the job application or job interview process, or from the start of your employment, or in the course of your employment, or throughout the duration of your service following a contract of service entered into between us and your employer, or (ii) from other sources, such as through companies in our Beiersdorf Group globally ("Beiersdorf Group"), recruitment websites, recruitment agencies, your employer (if you are outsourced workers), our service providers and other third parties (e.g. hospitals, insurance companies, financial institutions, background checking service providers), government authorities (e.g. Student Loan Fund), your reference persons and publicly available sources.

As applicable to you depending on your roles and responsibilities, we may collect, use and/or disclose the following categories and types of Personal Data about you:

  • Personal and contact details: such as your name, last name, address, email address, telephone number, social media information, photograph, gender, age, nationality, date of birth, marital status, number of children, blood type, weight and height, occupation, income, signature, copies of or information on government-issued documents (e.g., national identification card, passport, Visa, tax identification number, driving license, car plate registration, house registration, name/last name change certificate, birth certificate, marriage certificate, death certificate, military record, and work permit) and bank account information;
  • Educational background and employment history: such as your resume, curriculum vitae (CV), application form, educational institution, evidence showing your qualification or education level, work history, recruitment history, previous company payslip and transcript;
  • Employment-related details: such as your interview results, position, department, zoning assigned, employee identification, employment agreement details, performance evaluation records, disciplinary information (e.g., records of misconduct or misbehavior), complaints, records or information on leave, late records, ability test/personality test results, training records and CCTV records;
  • Information about your salary and benefits: such as your salary or wage rate, overtime payment, monthly and yearly diligent payment, allowances, disbursements, reimbursement information and documents information relating to provident fund entitlement, social security fund entitlement, cremation fund entitlement, family and child monetary support entitlement, business trip information, transport entitlement and group insurance information;
  • Sensitive Personal Data: such as religion (contained in government-issued documents), health data, criminal records, disability and labor union information. We will only collect, use, and/or disclose sensitive Personal Data on the basis of your explicit consent or where permitted by law.

If you provide Personal Data of other individuals (e.g. your family members, guarantors and reference persons) to us or you request us to disclose Personal Data of such individuals to other third parties, you are responsible to inform such individual of this Privacy Notice and obtain consents where applicable or necessary to permit us to use the Personal Data in accordance to this Privacy Notice. You should ensure that the Personal Data provided to us is accurate, up to date and complete. You also responsible for updating us on any changes to the Personal Data. 

2. Minors, quasi-incompetent and incompetent persons

As required by law in certain cases, we cannot collect, use, and/or disclose the Personal Data of minors, quasi-incompetent or incompetent persons in absence of parental or legal guardian consent. If you are under the age of 20, quasi-incompetent or incompetent persons, please ensure that consent from the holder of parental responsibility or legal guardian is obtained when it is required. Where we learn that we have unintentionally collected Personal Data from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent or incompetent persons without consent from their legal guardians or where we cannot rely on other legal bases apart from consent, we will immediately delete, destroy or de-identify such Personal Data, or process only if we can rely on other legal bases apart from consent.

3. Purposes of the collection, use and/or disclosure of your Personal Data

Except in limited instances when we can only use your Personal Data if you consent, we collect use, and/or disclose your Personal Data on the legal basis of (1) pre-contractual and contractual basis, for our initiation or fulfilment of a contract with you; (2) legal obligation, for the fulfilment of our legal obligations (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties, to be balanced with your own interest and fundamental rights and freedoms in relation to the protection of your Personal Data; (4) vital interest, preventing or suppressing a danger to a person’s life, body or health; (5) public interest, for the performance of a task carried out in the public interest or for the exercise of official actions and (6) the reason for an establishment and defence of legal claims, for the purposes defined below.

  • Recruitment and/or employment management: such as processing your application for employment, suitability evaluation and qualification assessment, background screening of you during the application process, making hiring decisions, determining pay eligibility in the performance of duties and the offer of reimbursements, communicating with you throughout the recruitment process (e.g. request for additional information, interview appointment) and executing an employment agreement;
  • Communicate with you: such as for internal communication within organization and communicating with your designated contacts in case of necessity and emergency;
  • Complying with applicable laws: such as to comply with legal obligations and requirements, legal proceedings, or government authorities’ orders and/or to cooperate with courts, regulators, government authorities, and law enforcement bodies; 
  • Protecting our interests: such as auditing (both internally and externally), monitoring misbehavior and preventing fraud, conducting internal investigations to follow up on suggestions, complaints, or claims, securing our premises and personnel which includes the use of CCTV and to establish, exercise, or defend our legal rights, including to carry out legal proceedings;
  • For the prevention or suppression of danger to a person's life, body, or health. 

In addition, we also collect use, and/or disclose your sensitive Personal Data for the following purposes on the consent or other legal bases as the case may be:

  • Health data for pre-employment/work health check-up, for provision of annual health check-up, for provision of benefits (e.g. health and dental benefits, fruit basket arrangements), for provision of insurance benefits and administration of insurance claims, for maintaining your absence/sick records, for COVID-19 screening and vaccination status checking, and for ensuring health and safety in the workplace;
  • Criminal records for background screening of you during the application process and making hiring decisions, for consideration on adjustment or change the positions or workplace, for disciplinary report, procedure, inspection and investigation;
  • Disability for allocation of employment for disabled; and
  • Labor union information for administrating and facilitating activities related to labor union. 

Failure to provide certain Personal Data may result in us not being able to perform certain processing activities described in this Privacy Notice, and as a consequence, we may not be able to comply with our obligations under your contract of employment/work relationship. In some instances, we may not be able to accept your employment or continue your work relationship with us. Also, this may affect responsibility for legal obligations that we or you are required to comply.

5. International data transfer

We may disclose or transfer your Personal Data to third parties located in countries outside of Thailand whose standard of Personal Data protection may not be equivalent to the level afforded in Thailand. In the event it is necessary to transfer your Personal Data to foreign countries which have lower standards of Personal Data protection, we will take steps and measures to ensure that your Personal Data is adequately protected, and that the recipient of your Personal Data have in place an appropriate level of data protection standards or other measures as applicable with the laws. If necessary, we may request your consent where consent to cross-border transfer is required by law.

7. Security measures

We maintain appropriate security measures for Personal Data, which cover administrative, technical and physical safeguards in relation to access control to protect the confidentiality, integrity, and availability of Personal Data against any accidental loss or unlawful or unauthorized access, use, alteration, correction or disclosure of Personal Data, in compliance with the applicable laws.

In particular, we have implemented measures on controlling access and use of devices for storing and processing Personal Data which are secured and suitable for our collection, use and/or disclosure of Personal Data. We also have measures on restricting access to Personal Data and the use of storage and processing equipment by imposing users' access rights, users' permission rights to the authorized personnel, and users' duties and responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of Personal Data, or theft of device used to store and process Personal Data. This includes measures on the re-examination in relation to access, alteration, erasure, or transfer of Personal Data which are in accordance with methods and channels used to collect, use and/or disclose Personal Data.

8. Your data protection rights

Subject to applicable laws and exceptions thereof, you may have the following rights to:

  • Access: You may have the right to access or obtain a copy of your Personal Data we collect, use, and/or disclose about you;
  • Rectification: You may ask us to have any inaccurate, outdated, incomplete, and misleading Personal Data we hold about you rectified;
  • Deletion: You may have the right to ask us to delete, destroy or de-identify Personal Data that we collect, use, and/or disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
  • Data Portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing your Personal Data on the basis of your consent or to perform our contract with you;
  • Objection: You may have the right to object to the collection, use and/or disclosure of your Personal Data for certain cases;
  • Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances;
  • Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use, and/or disclosure of your Personal Data is unlawful or noncompliant with applicable data protection laws; and
  • Withdraw Consent: You can withdraw your consent at any time, to the extent permitted under the applicable laws, where we collect, use and/or disclose your Personal Data based on your consent. 

We will try to respond to your request as quickly as possible within the timeframe prescribed by the applicable laws. 

Your request for exercising any of the above rights may be limited by the applicable laws. There may be certain cases where we can reasonably and lawfully decline your request, for example, due to our legal obligation or court order. If we decline your request under this section, we will notify you of our reason.  

9. Contact us

If you have any queries or concerns about your Personal Data under this Privacy Notice or where you wish to exercise your rights relating to your Personal Data, you can reach us or our Data Protection Officer at: 

1) Beiersdorf (Thailand) Co., Ltd.:

Head Office

  • 6th and 7th Fl., Sathorn Square Office Tower, 98 North Sathorn Road, Silom, Bangrak, Bangkok 10500 
  • Senior HR Operations Manager 02 820 8000 at 8.30 AM – 17.30 PM

Factory

  • 163 Bang Plee Industrial Estate, Bangna-Trad Road, Km 24 Bangsaothong, Amphur Bangsaothong, Samutprakarn 10570
  • Senior HRBP & Rewards Manager 02 030 6000 at 8.30 AM – 17.30 PM

2) Data Protection Officer (DPO):

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