Privacy policy

We collect information about you to make your job search as easy and safe as possible. This data is important; we understand that. This is why we’re committed to protecting your privacy online.

We’ve updated our privacy policy to explain exactly how we manage and use your information. This short film explains the changes in more detail.

At Michael Page, your privacy matters 

Michael Page International Recruitment (Thailand) Limited (“Michael Page”, “we”, “us”, or “our”) is part of the PageGroup PLC an international human recruitment consulting services group of companies and trades under the brands of brands Michael Page, Page Personnel, Page Executive and Page Outsourcing.  

We are committed to protecting the privacy of our candidates, clients and users of our website. 

We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this Privacy Policy. 

Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligations under Personal Data Protection Act B.E. 2562 (2019) of Thailand (“PDPA”), and other relevant laws and regulations that may be applicable. 

  1. Scope

Protecting your personal data is our priority. This privacy policy explains how we process and protect personal data about: 

  • candidates who register with us for roles that we are managing for other employers and for roles within our group companies, or through our website, job boards, social media sites or other sources; 
  • prospective candidates; 
  • prospective clients; 
  • business contacts at our clients and suppliers; and 
  • users of our websites 

(collectively "you" or “your"). 

It also tells you about your privacy rights including your right to object to our collection, use, or disclosure of your personal data or withdraw your consent. If you would like to contact us, please see the “How to Contact Us” section of this policy. 

  1. Personal data we collect

Candidates 

When you register with us as a candidate to provide work finding services to you, we may collect your personal data, including but not limited to your name, contact details and information from your CV. We may also collect information relating to your health (for example, disability information for reasonable work adjustment purposes), diversity information, including race, ethnic origin, sexual orientation and religion (for equal opportunity monitoring purposes) as well as details of any unspent criminal convictions where required by a client or by us, if you apply for a role with us. The PageGroup entity acting as Data Controller of your data in this case will be the one managing the collection of your personal data.  

If you use our website, click on links in emails we send to you, open or forward them, or sign up to receive job alerts or other contents from us, we also collect personal data from those interactions. 

We also obtain personal data about you from third parties, including, 

  • referees - when you are offered a job; 
  • former employers - to confirm dates of employment; 
  • educational institutions - to check your academic qualifications; 
  • credit reference agencies - if we need to check your financial standing; 
  • publicly available sources such as LinkedIn and social media sites to enhance the information we hold about you, in order to help us find more suitable roles for you; 
  • clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV. 

Prospective Candidates 

We collect personal data about you including your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn, and social media websites, so that we can contact you if we think you may be interested in our work finding services at a future date. We may also obtain your personal data through another candidate or an employer who recommends you as a contact.  

Prospective Clients 

We collect your contact details, your company’s contact details and data relating to your function or position or your company to establish commercial relationships with you and your company.  

Users of our website or apps 

We collect personal data such as your IP address and other data about your device which we need to provide our online content to you. We also collect data about your engagement with our website or apps such as the pages you view. If you contact us, we will also collect information about your enquiry. We use cookies and similar technologies to collect a lot of this information and our cookie policy tells you more about this.  

Clients 

We collect personal data such as your name, job title and contact details. We also process personal data about what communications we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent to you. We also collect feedback that you provide about our candidates. The PageGroup entity that will act as Data Controller in this case will be the entity that is the counterparty in the contract we sign with you or with the company you represent. 

If you provide information to us about a candidate (for example, if you confirm a candidate has worked with you or if you provide a reference), then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to us about that candidate. 

We collect personal data about you from public domain sources such as LinkedIn and social networking sites, or because you were a delegate at one of our events or at an event where the event organiser is permitted to share delegate details with us. 

Suppliers 

We typically collect your name and contact details as a business contact for your organisation.  

  1. Providing your personal data

In some cases, it will be necessary for you to provide personal data to us for us to work together. If you don’t provide us with the personal data we request for, we may not be able to provide you with our services effectively. 

  1. How we use your personal data

Candidates 

We use your personal data to:  

  • provide you with work finding services; 
  • communicate with you; 
  • enable you to upload your CV and apply for jobs; 
  • personalise your experience by creating a candidate profile; 
  • enable us to monitor equality and diversity; 
  • provide you with interviewing and salary advice and 

send you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices. 

We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest. We target these ads based on your previous interactions with our website, emails and through your engagements with our consultants. Your interaction with our ads may be used to measure the effectiveness of our ad campaigns and to improve our marketing strategy. This processing is carried out via Cookies and only if you have previously provided consent. 

Prospective Candidates and Clients 

We use your personal data to: 

  • determine if you may be interested in our services and how we can assist you; 
  • to contact you and find out if you are interested in our services. 

Users of our website or apps 

We may use your personal data to: 

  • improve and personalise your experience when you use our website or apps; and 
  • personalise advertising you receive from us. 

Clients 

We may use your personal data: 

  • to provide recruitment services to you; 
  • to communicate with you; 
  • to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services; 
  • to maintain our business relationship with you; 
  • to answer your enquiries when you contact us; 
  • to fulfil contractual obligations to you; 
  • to establish, exercise or defend legal claims; and 
  • for marketing purposes. 

Suppliers 

We use your personal data: 

  • to communicate with you; 
  • to maintain our business relationship with you; 
  • to answer your enquiries when you contact us; 
  • to fulfil contractual obligations to you; 
  • to establish, exercise or defend legal claims; and 
  • for marketing purposes. 

You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. We have also established a marketing preference centre where you can view and make decisions about your marketing preferences and opt out of receiving marketing from us at any time. 

  1. Legal Grounds for processing your Personal Data

Under the PDPA, we rely on the following legal grounds to process your personal data: 

(a) Performing a contract - in order to perform our obligations under a contract with you, for example where clients contract for services and candidates accepting our terms and conditions. Or in respect of prospective clients or candidates to take steps that would be necessary in order to enter into a contract with us.  

(b) Compliance with a legal obligation - where we need to process your personal data to comply with legal or regulatory obligations. 

(c) Our legitimate interests or those of a third party - including: 

  • responding to your requests and enquiries (the legitimate interest of our group companies in this case is to maintain a constant and updated communication with clients and candidates, which is part of any commercial relationship); 
  • optimising the performance of our website and user experience; 
  • contacting prospect clients in order to establish commercial relationships with clients (the legitimate interest of Page is to maintain relations of any kind with the company where the contact person works); 
  • informing you about our services, job opportunities, industry reports and insights, events, promotions and competitions (the legitimate interest of Page is to inform clients and candidates about similar services and products); and 
  • providing satisfaction surveys of our services. 

We have performed a legitimate interest assessment in order to confirm that our interests are not overridden by your interests or fundamental rights and freedoms. You can ask for this assessment using the contact details below. 

(d) Consent in some circumstances, we will ask for your consent to process your personal data. For example, if you register for a job, we will offer you the possibility of registering for similar job alerts. To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. Please contact us if you would like to withdraw your consent. 

  1. Automated Decision Making and Profiling

We do not take decisions based solely on automated processing; there is always human intervention before taking a decision. 

We perform two types of profiling based on candidate’s personal data: 

  • JobMatch is a tool available on our website for candidates to upload their CVs so we can recommend jobs that align to your skills. However, this profiling does not restrict nor excludes access to other jobs and positions. 
  • Intelligent search within our customer database enables us to filter through CVs when we receive many applications for roles that we advertise, and to enter relevant key words such as years of experience or field of practice. It then analyses all the CVs uploaded into it and delivers a smaller pool of candidates by matching the key words in candidates’ CVs and ranking the candidates according to their suitability for the role. As explained above, there is always a recruiter who verifies this process, so there are not automated decisions. 

Please note that none of this profiling activities produce legal or similar significant effects to candidates, however if you would like to know more, please contact us. 

  1. Who we share your personal data with

While your personal information will be kept confidential, in certain circumstances, it may be necessary for us to provide or disclose your personal information if required for any of the foregoing purposes. Where we do so, we would merely disclose information that is necessary for the purpose of such disclosure.  

Other companies within our Group 

Michael Page is part of the PageGroup PLC, a group of companies which operates globally. Our recruitment experts and key members of the business who run functions such as payroll and IT support are based around the world. We may share with or give access to your personal information to other companies within our PageGroup PLC. You can find a list of PageGroup PLC entities and the countries where they are located here. 

For example, where appropriate for your job search or if you are looking for qualified professional to join your organisation or a recruitment partner, we may share your personal data with our recruiters specialised in fields such as Technology and Outsourcing who are based either in Turkey or the Philippines (please refer to entity list above). They process your personal data on behalf of other group entities as it may be applicable (please refer to entity list above). An appropriate level of data security is ensured for this share and transfer on the basis of the company’s intragroup agreement and Standard Contractual Clauses (“SCCs”) as described below. 

We have in place an intra-group information transfer agreement containing Standard Contractual Clauses (“SSCs”) approved by the UK Parliament for the transfer of personal information to “third countries”. These SSCs act as an additional safeguard to permit cross-border transfers of personal information from within the European Economic Area (“EEA”) to third countries outside the EEA, (as information protection laws outside the EEA may not provide an equivalent level of protection to EEA information protection laws).  If you would like a copy of the SSCs, please contact us.  

The purposes of sharing your personal data within PageGroup PLC companies are i) providing essential services which are centralised in one single entity such as IT, commercial and sales support services, in this case these entities will access and process your personal data as data processors, following the instructions of your data controller, ii) managing global, regional or senior executive positions, or the development of key accounts, which would require the cooperation of different companies across the group, and iii) managing positions that can be fulfilled remotely.  

The applicable lawful basis to these processing activities is the performance of the contract with clients and candidates or to take steps necessary to enter into a contract, and the legitimate interests of PageGroup PLC in delivering its services using internal resources. 

Please note, that if you register as a candidate in a different country than the one in which you originally joined PageGroup PLC, a unique record will be created for you. A single record avoids duplicities and improves accuracy of the personal data. For these purposes, the PageGroup PLC companies involved will share your personal information as independent data controllers.  

Third Parties 

If you are a candidate, we share your personal data with clients who have vacancies for jobs which you are interested in.  

We also share your personal data and, where necessary and permitted by the law, special category data with third party service providers who perform services and functions on our behalf, such as: 

  • conducting employment reference checks; 
  • conducting qualification checks; 
  • carrying out criminal convictions checks (as required); 
  • verifying details you have provided from third party sources; 
  • conducting psychometric evaluations or skills tests; 
  • hosting personal data for us; 
  • providing professional advice to us; 
  • providing data analytics to us; 
  • carrying out testing and development work on our business technology systems;  
  • administering surveys or competitions on our behalf; 
  • assisting us to communicate with you; and 
  • providing research and mailing house or other marketing services. 

We contractually require minimum standards of confidentiality and data protection from our third party service providers. If we need to send personal data outside the EEA, we will ensure that adequate safeguards are in places.  

In addition, due to requirement of PDPA, in the event that we send or transfer your personal data collected by the data controller who is subject to PDPA to countries other than Thailand, we will ensure you that the destination countries or international organizations receiving such personal data have adequate or better data protection standard than that required by PDPA, except in the following circumstances: 

  • where it is for compliance with the law; 
  • where your consent has been obtained, provided that you have been informed of the inadequate personal data protection standards of the destination countries or international organizations receiving your personal data; 
  • where it is necessary for the performance of a contract to which you are a party, or in order to proceed as requested by you prior to entering into a contract; 
  • where it is for compliance with a contract between us and other persons or juristic persons for your interests; 
  • where it is to prevent or suppress a danger to the life, body, or health of you or other persons, when you are incapable of giving the consent at such time; 
  • where it is necessary for carrying out the activities in relation to substantial public interest. 
  1. Other Disclosures

In addition, we may disclose your personal data: 

  • if we are legally required to do so; 
  • to law enforcement agencies, regulators or other government officials; and 
  • to the new business owners and their advisers in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business. 

Keeping your personal data secure 

We have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Only authorised personnel and third party service providers are provided with access to personal data on a need to know basis, and these employees and service providers are contractually obliged to treat this information as confidential. 

How long we hold your personal data for 

We will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for, which may be an ongoing purpose. For example, if you’re a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers. 

We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data. 

Where we process your personal data for marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you marketing materials or not to process your data indefinitely, so that we can respect your request. 

Your rights in relation to personal data we hold about you  

You have several rights under PDPA. These rights include the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data; to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this data to another controller. 

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). 

These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of the impact or effect of your request or from request for withdrawal of your consent and any relevant exemptions we are relying on when we respond to your request.  

For avoidance of doubt, if your personal data is collected, used or disclosed by the data controller who is subject to PDPA, you have the following rights under PDPA: 

  1. You may withdraw your consent at any time. The withdrawal of consent shall be as easy as to giving consent, unless there is a restriction of the withdrawal of consent by law, or the contract which gives benefits to you. However, the withdrawal of consent shall not affect the collection, use, or disclosure of personal data that you have already given consent. 
     
  2. You are entitled to request access to and obtain copy of the personal data related to you, which is under the responsibility of the data controller who is subject to PDPA, or to request the disclosure on the acquisition of the personal data obtained without your consent. 
     
  3. You have the right to receive your personal data from the data controller who is subject to PDPA. The data controller shall arrange such personal data to be in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means. You are also entitled to: 
    • (1) request the data controller to send or transfer the personal data in such formats to other data controllers if it can be done by the automatic means;
    • (2) request to directly obtain the personal data in such formats that the data controller sends or transfers to other data controllers, unless it is impossible to be done technically. 
       
  4. You have the right to object the collection, use, or disclosure of your personal data, at any time, in the following circumstances: 
    • (1) Where the personal data is collected with the exemption to consent requirements under PDPA, unless the data controller can prove that: 
      • (a) the collection, use, or disclosure of such personal data can be demonstrated by the data controller that there is a compelling legitimate ground; 
      • (b) the collection, use, or disclosure of such personal data is carried out for the establishment, compliance or exercise of legal claims, or defense of legal claims;
    • (2) the collection, use, or disclosure of such personal data is for the purpose of direct marketing;
    • (3) the collection, use, or disclosure of the personal data for the purpose of scientific, historical or statistic research, unless it is necessary to performance of a task carried out for reasons of public interest by the data controller. 
       
  5. You have the right to request the data controller to erase or destroy the personal data, or anonymize the personal data to become the anonymous data which cannot identify you in the following events: 
    • (1) the personal data is no longer necessary in relation to the purposes for which it was collected, used or disclosed; 
    • (2) you withdraw consent on which the collection, use, or disclosure is based on, and where the data controller has no legal ground for such collection, use or disclosure; 
    • (3) you object to the collection, use, or disclosure of the personal data and the data controller cannot reject such request as mentioned above, or where you exercise your right to object the collection, use, or disclosure of your personal data for the purpose of direct marketing; 
    • (4) the personal data have been unlawfully collected, used, or disclosed under PDPA. 
       
  6. You have the right to request the data controller who is subject to PDPA to restrict the use of your personal data in the following events: 
    • (1) when the data controller is in the process of examination to ensure that the personal data remains accurate, up-to-date, complete, and not misleading as requested by you; 
    • (2) when it is the personal data which shall be erased or destroyed, but you request the restriction of the use of such personal data instead; 
    • (3) when it is no longer necessary to retain such personal data for the purposes of such collection, but you have necessity to request for the retention of same for the purposes of the establishment, compliance, or exercise of legal claims, or the defense of legal claims; 
    • (4) when the data controller is in the verification process under item 4. (1) and item 4. (3) in order to reject the objection made by you under item 4. 
       
  7. In the case where you request the data controller to ensure that the personal data remains accurate, up-to-date, complete, and not misleading, if the data controller does not take action as per your request, the data controller shall record such request together with reasons.
     
  8. You have the right to file a complaint in the event that the data controller or the data processor, including the employees or the service providers of the data controller or the data processor violates or does not comply with PDPA and its notifications. 
  1. How to Contact Us

You can contact our Privacy Officer by writing to us at our email address or postal address below, if you wish to request for access to your personal information held by us, request that your personal information be updated or corrected, or withdraw your consent to the processing of your personal information by us. If you would like to have any further information, or if you have any comments about this Privacy Policy or any questions or complaints on any privacy issue, this should also be communicated to us in the same manner. 

Contact details: Privacy Officer 

Email: PrivacyofficerAPAC@michaelpage.com 

Post: The Data Privacy Officer 

No. 689 Bhiraj Tower at EmQuartier 

41st Floor, Unit 4108-4109 

Sukhumvit Road 

North Klongton 

Vadhana, Bangkok 10110 THAILAND 

  1. Changes to our Privacy Policy

We may amend this privacy policy at any time without prior notice to you if the amendment is not related to the requirements or obligations under PDPA. 

We suggest that you visit our website regularly to keep up to date with any changes.