Cornerstone Global Partners Data Protection Policy
Cornerstone Global Partners(Vietnam) Company Limited (hereinafter referred to as “CGP Vietnam”, “we”, “us” or “our”) is committed to protecting users’ and subscribes’ (“your”) privacy to the Vietnam personal data protection principles.
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations in which we have engaged to collect, use, disclose, or process personal data for our purposes.
Application of This Policy
CGP Vietnam is part of the CGP Group, a recruitment business serving specialist markets across APAC – Singapore, Malaysia, Thailand, Vietnam, Japan, Mainland China, and Hong Kong as well as in the Middle East and the USA.
This Policy is an addendum to our data collection form and should be retained as part of the whole document for the process. We collect the personal data of the following types of people (hereinafter referred to as “users”) to allow us to undertake our business:
Prospective and placed candidates for permanent, temporary, or contract roles.
Prospective and live client contacts.
Supplier contacts to support our services.
Employees, candidates’ referees, consultants, and temporary workers.
Attendees of events run by CGP Vietnam.
Personal Data We Collect About You
As used in this Policy, “personal data” means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
date of birth；
residence information (including permanent address, temporary address, current address, hometown, contact address)；
mobile number, national identification number, personal identification number, passport number；
educational and employment history (including reference documents)；
and any additional information provided to us by you.
And some sensitive personal data includes:
health-related information in health examination reports, information in judicial background reports that you provide (if applicable)；
information about your income (if applicable) ；
information about your ethnicity, religion, and political affiliation (if applicable).
We collect Personal Data when you give it to us by filling in forms on one of our websites, or by corresponding with us by phone, e-mail, or otherwise. With regards to your website visit, we will automatically collect technical information, your login information if applicable, browser type and version, browser plug-in types and versions, operating system, and platform.
We may gather information about you from various sources, including but not limited to LinkedIn, corporate websites, job board websites, online CV libraries, business cards, and personal recommendations.
Collection, Use, and Disclosure of Personal Data
We generally collect personal data that you knowingly and voluntarily provide in the course of or in connection with your employment with us, or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”, which may include your job placement agent), after
you (or your authorized representative) have been notified of the purposes for which the data is collected, and
you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or
Collection and use of personal data without consent is permitted or required by the PDPD or other laws, including:
In emergency cases where it is necessary to immediately process relevant personal data to protect the life or health of the data subject or others
Public disclosure of personal data is in accordance with the law
Processing data is carried out by a relevant authority in the event of emergency on national defense, security, social order and safety, major disaster, or dangerous epidemic; or when there is a risk that threatens security and national defense but not to the extent where it is necessary to declare a state of emergency; or to prevent and combat riots, terrorism, crimes and violations of the law
To fulfill the contractual obligations of the data subject with relevant entities as prescribed by law
To serve the activities of the authority as prescribed by sector-specific laws
We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law).
As a user, your personal data will be collected, used, and may be disclosed by us for the following purposes:
Assessing and evaluating your suitability for employment in any current or prospective position within the organization;
Verifying your identity and the accuracy of your personal details and other information provided;
Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;
Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Vietnam or abroad, for the aforementioned purposes;
and any other incidental business purposes related to or in connection with the above.
As a user, if you provide any individual personal data other than your personal data to us, you should obtain consent for collection, use, and disclosure from the individual before disclosing the personal data to us.
You have the right to restrict data processing and the right to object to data processing. CGP will carry out the restriction of data processing within 72 hours after the request, with all personal data you request to restrict unless otherwise provided by law. CGP will fulfill the request of the data subject within 72 hours after receiving the request unless otherwise provided for by law.
How Can You Withdraw the Consent?
The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing via email. You may withdraw consent and request us to stop collecting and/or using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email to our Data Protection Officer at the contact details provided.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and take effect your request within 10 business working days of receiving the request. However, if we are unable to complete your request within the timeline, we will inform you within 10 business days.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your request. We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing via email.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
PLEASE NOTE THAT IF YOU WITHDRAW YOUR CONSENT FOR US TO USE, DISCLOSE, STORE, OR PROCESS YOUR PERSONAL DATA FOR THE PURPOSES MENTIONED ABOVE, WE MAY NOT BE ABLE TO CONTINUE PROVIDING SERVICES TO YOU OR FULFILL ANY CONTRACTUAL OBLIGATIONS WITH YOU, AND WE WILL NOT BE HELD RESPONSIBLE IN THE EVENT THAT WE CEASE PROVIDING SERVICES OR FULFILLING OUR CONTRACTUAL OBLIGATIONS. IN SUCH A CASE, OUR LEGAL RIGHTS AND REMEDIES WILL STILL BE EXPRESSLY RESERVED.
Access to your Personal Data
If you wish to make an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data you may submit your request in writing via email to our Data Protection Officer at the contact details provided below. Access request must be written in Vietnamese and include the following information: (1) the requestor's full name, residential address, ID number, and contact details; (2) the data and format to be provided; (3) The reasons for the request.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your access request within 72 hours. If we are unable to provide you with any personal data requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPD).
Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organization has on record if the record of your personal data forms a negligible part of the document.
Correction of Personal Data
If you wish to make a correction request to correct or update any of your personal data which we hold, you may submit your request via email to our Data Protection Officer at the contact details provided below.
We will respond to your correction request within 72 hours. If we are unable to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so within 72 hours (except where we are not required to do so under the PDPD).
Protection of Personal Data
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus and firewall protection, encryption, and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing via email at the contact details provided below.
Retention of Personal Data
We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.
Upon confirmation of a successful job application, your personal data provided in the job application will be kept as employment data.
We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
We may share data with our contracted third-party service providers who may be located in other countries. These third-party service providers provide a variety of services to us. This includes but is not limited to, data storage, recruitment agency software, etc. Before we do so, we will take steps to ensure that your personal data will be given adequate protection as required by relevant data protection laws and internal policies.
We may use and may disclose your personal information to third parties outside of Vietnam for the purposes it was collected, or for a related or ancillary purpose in connection with the performance of our business activities or operation of our business functions including but not limited to:
Any subsidiary and affiliated companies of CGP;
Clients who may wish to engage your services as a contractor or temporary employee;
Our suppliers, service providers, or partners, including (but not limited to) organizations that conduct competency or psychometric tests, payroll processing, or other employment-related services;
Your nominated referees; and
Any educational or vocational organizations to the extent necessary to verify your qualifications.
We operate in different markets and countries. From time to time, it is likely that we may need to transfer your data overseas in connection with our provision of services. The country or countries to which your data may be transferred is not restricted and may include: The USA, Mainland China, Hong Kong SAR, Singapore, Japan, Malaysia, or other countries/regions from time to time.The data transferred overseas is protected to a standard comparable with the PDPD in Vietnam.
Your Rights and Choices
IF YOU CHOOSE NOT TO REGISTER OR PROVIDE PERSONAL INFORMATION, YOU MAY NOT BE ABLE TO USE A SIGNIFICANT PORTION OF OUR SERVICES.
You also have choices regarding cookies. By changing your browser preferences, you can choose to accept all cookies, be notified when a cookie is set, or reject all cookies. IF YOU CHOOSE TO REJECT ALL COOKIES, YOU MAY NOT BE ABLE TO USE OUR SERVICES THAT REQUIRE REGISTRATION. These services include identifying newly posted jobs since your last visit, automatic login, and the saved jobs feature. However, you can still use most features of the platform even if you do not accept cookies.
Effect of Policy and Changes to Policy
This Policy applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgment and acceptance of such changes.
Consent Clause for User
You acknowledge that you have read, understood, and agree to the above Policy, and consent to the collection, use, and/or disclosure of your personal data by us for the purposes set out in the Policy.
In the event that you submit job application or your personal data via any third party to us for the purposes set out in the Policy, you warrant that such third party has been duly authorized by you to disclose your personal data to us for the purposes set out in the Policy.
In the event that you submit job application or personal data on behalf of any third party for the purposes set out in the Policy, you warrant that you have been duly authorized by such third party to disclose his or her personal data to us for the purposes set out in the Policy.
You acknowledge that the personal data provided by you is accurate and complete.
What to do if you have a problem or question?
You may contact us if you have any inquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner.
Address: Level 2, Sonatus Building, 15 Le Thanh Ton, District 1, HCMC, 70000, Vietnam