Privacy Notice

Last Updated 15 June 2021

Rakan Tutor (“Rakan Tutor,” “we,” “us,” “our” or the “Organisation“) and its group entities (collectively, the “Group“) are committed to protecting the privacy and security of your personal information.

This Privacy Notice for Staff (this “Notice”) describes how we collect and use personal information about you, during and after your working relationship with us, in accordance with applicable law. You should refer to Rakan Tutor’s Privacy Policy (the “Policy”), which is available in the “Policies” section of Rakan Tutor’s website (the “Website”).  This Notice does not form part of any contract of employment or other contract to provide services and does not confer any contractual rights on you, or place any contractual obligations on the Organisation.  We may update this Notice at any time and from time to time.

It is important that you read the Policy (please ensure you are looking at the most recent version) and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.

  1. Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: Rakan Tutor, Unit 79-1, Biz Avenue II @ Neocyber, Lingkaran Cyber Point Barat, 63000 Cyberjaya, Selangor or email [email protected] We aim to respond within 30 days from the date we receive privacy-related communications.

  1. How do we collect personal data?
    • Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who correspond with us in any way and form, complete our online forms, subscribe to our newsletters and preference centre, register for webinars, attend meetings or events we host, visit our offices for recruitment purposes or performance of services in relation to our activities. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications. 
    • Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our partners. We may attach personal data to our management records to better understand the services in connection with our offerings, to satisfy a legal obligation, or to pursue our legitimate interests. 
      • Public sources. Personal data may be obtained from public registers, news articles, sanctions lists, and Internet searches (including social media).
      • Social and professional networking sites. If you register or login to our websites using social media or email address to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
  1. What categories of personal data do we collect?

We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through engagements, from applicants, our partners and through other situations including those described in this Privacy Notice. 

    • Personal data. Here is a list of personal data we commonly collect to conduct our business activities. 
      • Personal details (e.g., name, gender, Organisation name, job title, work and mobile telephone numbers, work and personal email and postal address).
      • Professional details (e.g., job and career history, educational background and professional memberships, published articles). 
      • Financial information (e.g., taxes, payroll, investment interests, assets, bank details, insolvency records).
    • Sensitive personal data. Examples of sensitive personal data we may obtain, or otherwise hold, include:
      • Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
      • Adverse information that may reveal criminal convictions or offences information.
      • Information provided to us by our clients in the course of a professional engagement.
      • Diversity and equal opportunity information volunteered by participants in certain professional empowerment programmes and onboarding processes.
    • Child data.Although we do not intentionally collect information from individuals under 13 years of age, we may occasionally receive details about children attending performances and other events we host with their family or guardians.
    • Location-based data.We may process geographical locations you enter when arranging or providing services to you.
  1. What lawful reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data to operate our activity and provide our products and services: 

    • Contract. We may process personal data in order to efficiently and safely perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.
    • Consent. We may rely on your freely given consent at the time you provided your personal data to us.  
    • Legitimate interests. We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include:
      • To deliver the services.
      • To deliver timely market insights\ and speciality knowledge.
    • Legal obligations. We may process personal data in order to meet our legal and regulatory obligations or mandates. 
  1. Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes: 

    • Performing internal arrangements in connection with the provision of our services.
    • Providing services in line with our offering.
    • Promoting our services, products and capabilities to existing and prospective individuals and businesses.
    • Personalising online landing pages and communications we think would be of interest.
    • Administering, maintaining and ensuring the security of our information systems, applications and websites. 
    • Authenticating registered users.
    • Processing online requests and queries, including responding to communications from individuals or requests for information.
    • Contacting journalists regarding Organisation press releases, invitations to press parties, highlighting messages that may be of interest on specific topics.
    • Travel arrangement assistance.
    • Helping to support with the running of development programs for education and learning purposes.
    • Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime. 
    • Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, and witness statements. 
  1. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them.

  1. Do we transfer your personal data outside the European Economic Area?

We may. Each organisation in receipt of the data is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.

  1. What are your data protection rights? 
    • You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
    • You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. 
    • You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
    • You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
    • In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another Organisation if is technically feasible.
    • You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
    • You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
    • You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

If you would like to exercise your Data Subject Rights, you can email [email protected] We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

  1. What about personal data security?

We have put appropriate technical and organisational security procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk. 

  1. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years. 

  1. Do we link to other websites?

Our websites may contain links to other sites, including sites maintained by other organisations that are not governed by this Privacy Notice. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.

  1. Do we change this Privacy Notice?

We regularly review this Privacy Notice and will post the updated version on the webpage. This Privacy Notice was last updated 15 June 2021.