Jaspal Public Company Limited (“Company“) recognises the importance of protecting the personal data that you have provided or may provide to the Company. Therefore, the Company has issued this Privacy Notice to inform and help you understand the details concerning the collection, use, and disclosure (collectively referred to as “Processing“) of your personal data in accordance with the Personal Data Protection Act B.E. 2562 (2019), including your legal rights as the data subject. The details are as follows:
This Privacy Notice applies to the personal data that the Company has received or collected from you in connection with your provision of personal data for the purpose of recruiting and accepting interns for internships and vocational training with the Company and/or for conducting other activities related to the internship and vocational training of interns with the Company. Therefore, the Company recommends that you read this Privacy Notice to be informed of and understand the methods, guidelines, and purposes by which the Company processes your personal data, as well as to be aware of your personal data rights and the Company’s contact channels.
“Intern” means students who apply for internships and vocational training with the Company.
“Personal Data” means any information relating to a person which can be used to identify such person, whether directly or indirectly, excluding data of deceased persons. Types of personal data include:
– General Personal Data: Such as name, surname, age, gender, nationality, date of birth, nickname, address, phone number, national ID number, passport number, social security number, taxpayer ID number, driver’s license number, bank account number, email address, vehicle registration number, etc.
– Sensitive Personal Data: Includes personal data related to race, ethnicity, political opinions, doctrines, religious or philosophical beliefs, sexual behaviour, criminal records, health information, disability, labour union information, genetic data, biometric data, or any other information that similarly affects the data subjects as specified by the Personal Data Protection Committee, of which the Company will proceed with special care. The Company will collect, use, and/or disclose Sensitive Personal Data only with your explicit consent or when the Company is legally required to do so.
However, the following information is not considered personal data: business contact information that does not identify a person such as company name, company address, company registration number, office phone number, work email address, email address of a company’s group such as info@company.co.th, anonymous data, or pseudonymous data which has been anonymised such that it cannot be used to identify a person by technical means, and data of deceased persons
“Data Subject” means an individual who owns the personal data, in this case, “you” as the Intern.
The Company may collect your personal data as necessary for the purposes of collection, use, or disclosure as specified in Article 5. And in order to inform you and help you understand the details in regard to your personal data that the Company collects, the Company hereby informs you of the details as follows:
Types of Personal Data |
Details of Personal Data |
|---|---|
|
Basic Personal Data |
Title, name, surname, age, gender, date of birth, national ID number, passport number, nationality, photograph, contact address, phone number, email address, |
| Education Data |
Educational records, educational qualifications, copies of academic transcripts. |
| Financial Data |
Bank account number. |
| Other Data |
Test or interview information, portfolio work, data recorded from closed-circuit television (CCTV), still images, and videos related to participation in various company activities. |
| Third-Party Data | Emergency contact person. |
If you have provided a copy of your national ID card to the Company, please be informed that the Company does not intend to collect and use information related to religions and blood types (if any) appearing on your national ID card. Therefore, we request that you conceal such information (if any), and in the event that you do not conceal such information as informed by the Company, you will be deemed to have given consent and permitted the Company to conceal such information on your behalf, and any documents with such concealed information will be considered legally valid and enforceable in every aspect.
Furthermore, in the event that you have provided the personal data of third parties (e.g., emergency contact persons) to the Company, the Company kindly requests that you inform such third parties of this Privacy Notice and that consent may be requested from such third parties as necessary unless another legal basis under the law permits otherwise.
Regardless, the collection, use or disclosure of your personal data requires consent from the Data Subject. The Company will explicitly request your consent in writing or by electronic means prior to, or during the collection of personal data. You have the right to refuse to provide your consent for the processing of your personal data. However, if you choose not to give your consent or withdraw your consent, it may affect the recruitment and acceptance of interns for internships and vocational training with the Company, and/or the conduct of any activities related to the internships and vocational training of interns with the Company to the extent necessary, which require complete and correct personal data.
Furthermore, the personal data you provide to the Company must be accurate, complete, truthful, and not misleading. You are required to keep your personal data up to date by informing the Company of any changes or updates through the contact channels of the Company as specified in Article 12 of this Privacy Notice.
4.1 Personal Data Provided Directly by You:
From the information filled out in the internship application form, attached documents for internship consideration and selection, tests or interviews, as well as any updates or changes to your data during the recruitment and acceptance process of interns for internships and vocational training with the Company, and/or any activities related to the internships and vocational training of interns with the Company.
4.2 Personal Data Received from Other Sources
The Company may collect your personal data from other sources, such as the university or institution where you are studying.
The Company will collect, use, and disclose your personal data with the purposes based on the legal basis for data processing and to align with the personal data collected as specified in Article 3. The purposes are as follows:
Purpose of Processing |
Legal Basis |
|---|---|
| Internship Recruitment | |
|
1. To consider and select internship applicants for internships and vocational training with the Company, which includes application processes through the following application channels:
|
- Contractual Basis - Legitimate Interest |
| After you have been selected as an intern of the Company | |
|
2. For the performance of the agreement during your internship with the Company, the Company will draft an internship agreement to confirm and formalise your acceptance into the internship program. This includes agreements on the framework of the internship, the internship duration, permission to use the Company’s properties as necessary for the internship, as well as execution of other relevant agreements, such as confidentiality agreements, compensation agreements, or scholarship agreements (if any). |
- Contractual Basis |
|
3. To evaluate your internship performance and provide feedback and suggestions on forms prescribed by your university or educational institution. |
- Legitimate Interest |
|
4. To coordinate during the internship period in cases of necessity or emergencies. |
- Legitimate Interest |
|
5. To manage the use of the Company’s information technology, such as applying for access to electronic systems or enabling access to or use of the internet or other electronic systems of the Company, creating a username and password to access computers and other technological tools within the Company. |
- Legitimate Interest |
|
6. For security purposes within Company buildings or premises, including exchanging access cards containing your personal data prior to entering into the Company’s offices/branch offices and recording images on the Company’s premises through close-circuit televisions (CCTV). |
- Legitimate Interest |
|
7. To manage the continuity of the Company's business, to understand and document decision-making in your role while undergoing your internship with the Company, and to retain knowledge within the Company after you complete your internship with the Company, and to maintain a database and verify your internship history. |
- Legitimate Interest |
|
8. For managing health and safety during your internship with the Company. |
- Legal Obligation - Legitimate Interest |
The Company may disclose your personal data to internal and external parties as necessary to fulfil the purposes specified in this Privacy Notice. The Company may send your personal data to the following parties:
6.1 Internal Parties
Your personal data may be disclosed or sent to various departments within the Company, but only to those that are relevant and have a role or responsibility, and only to the extent necessary for the stated purposes, as follows:
6.2 External Parties
Your personal data may be disclosed or sent to the following external organisations or third parties:
For external parties to whom the Company may disclose your personal data, appropriate measures are in place to ensure that your personal data is protected and secure.
Additionally, in the event that you provide consent for the Company to disclose your personal data to the institution or organisation where you are applying for a job, or to your employer, the Company may disclose your information to certify the completion of your internship.
In cases where it is necessary to transmit or transfer your personal data abroad, the Company will comply with the Personal Data Protection laws and take appropriate measures to ensure the protection of your personal data and allow you to exercise your rights relevant to your personal data as stipulated by law. The Company will also require the recipient of your personal data to implement adequate safeguards and process your personal data only as necessary.
The Company will retain your personal data only for as long as necessary for the purposes stated in this Privacy Notice unless the law requires a longer retention period. The Company will retain your personal data for a period not exceeding 10 years from the date of completion of your internship with the Company, for the purpose of verification in case of disputes within the statute of limitations as prescribed by law.
In the event that the period of retention has elapsed or the retention of your personal data becomes unnecessary, the Company will delete, destroy, or anonymise such personal data.
In the event that the Company collects, uses, or discloses your personal data for the purposes specified in this Privacy Notice, you have the following rights under the Personal Data Protection Act B.E. 2562 (2019):
9.1 Right to Withdraw Consent
If you have given consent to the Company for the collection, use, and/or disclosure of your personal data (whether such consent was given before or after the enforcement of the Personal Data Protection Law), you have the right to withdraw your consent at any time while your personal data is with the Company, unless there are legal restrictions or contractual obligations that benefit you.
The withdrawal of your consent may affect job consideration, various benefits that you may receive from the Company, or the ability to receive beneficial information. Therefore, it is beneficial for you to study and inquire about the potential impacts before withdrawing your consent.
9.2 Right to Access
You have the right to access your personal data and request a copy of your personal data that is under the Company’s responsibility. You may also request that the Company disclose the source of your personal data that is in the possession of the Company.
The Company may refuse your request to access and obtain a copy of your personal data if doing so would adversely affect the rights and freedom of other individuals, or if the Company is required by law or a court order to withhold such personal data.
9.3 Data Portability Right
You have the right to obtain your personal data in the event that the Company has prepared such personal data in a readable or usable format by automated tools or devices and where such personal data can be used or disclosed in an automatic manner. You also have the right to request the Company to send or transfer the personal data in the foregoing formats to another data controller where such process can be done by automated means, and you also have the right to request the personal data which the Company sends or transfers in the foregoing formats to another data controller directly unless otherwise technically unfeasible.
However, the foregoing personal data must be the data you provided consent for the Company to collect, use, and/or disclose, or the personal data that the Company is required to collect, use, and/or disclose to provide you with services of the Company as per your agreement with the Company, or other personal data as specified by the legally authorised entity.
9.4 Right to Object
You have the right to object to the collection, use, and/or disclosure of your personal data at any time if the collection, use, and/or disclosure of your personal data is carried out for operations necessary for the legitimate interests of the Company or of another person or juristic persons, within reasonable expectations, or for the performance of a task carried out in the public interest. If you object, the Company will still continue to collect, use, and/or disclose your personal data only where the Company can demonstrate legal grounds that outweigh your fundamental rights, or for the establishment of legal rights, legal compliance, or defence of legal claims in litigations as applicable.
9.5 Right to Erasure
You have the right to request the deletion or destruction of your personal data, or to have your personal data anonymised if you believe that your personal data has been unlawfully collected, used, and/or disclosed, or if you find that it is no longer necessary for the Company to retain your personal data for the purposes stated in this Privacy Notice, or when you have exercised your right to withdraw consent or object as stated above, unless in the cases where the Company must retain the data for legal compliance or to exercise its legal rights in relation to the retention of such personal data.
9.6 Right to Restrict Processing
You have the right to request the temporary suspension of the use of your personal data in cases where the Company is verifying your request for correction of personal data or objection, or in any other case where the Company no longer needs to retain and must delete or destroy your personal data in accordance with applicable laws, but you request the Company to suspend its use instead.
9.7 Right to Rectification
You have the right to request that the Company correct your personal data to be correct, up-to-date, complete, and not misleading.
9.8 Right to Lodge a Complaint
You have the right to file a complaint with the relevant legal authorities if you believe that the collection, use, and/or disclosure of your personal data has been conducted in a manner that violates or does not comply with the applicable laws.
If you have any concerns or questions about the Company’s practices regarding your personal data, please contact the Company using the contact details provided in Article 12 of this Privacy Notice. In the event that there is reasonable evidence to believe that the Company has violated the Personal Data Protection Law, you have the right to file a complaint with the Expert Committee appointed by the Personal Data Protection Committee in accordance with the regulations and procedures specified by the Personal Data Protection Law.
If you wish to exercise the rights stipulated above, you must contact the Company using the contact details provided in Article 12 of this Privacy Notice by submitting a written request. The Company will make its best endeavour to consider and respond to your request without delay, or within the time frame specified by law. However, any request to exercise these rights may be limited subject to the relevant laws, and in some cases, the Company may refuse or is unable to proceed as requested as appropriate and on lawful grounds such as where the law grants the right to deny such requests.
The Company has implemented appropriate security standards to prevent the loss, unauthorised access, use, alteration, or disclosure of personal data without authorisation or improperly. and the Company will review these measures as necessary, or when technology changes, to ensure the effectiveness of the security measures as appropriate.
The Company reserves the right to amend this Privacy Notice as necessary and appropriate. Any changes will be announced and displayed on the Company’s website or by other appropriate means.
If you have any questions related to this Privacy Notice, or if you wish to exercise your rights as outlined in Article 9, or if you have any complaints, you can contact the Company at:
Data Controller
Jaspal Public Company Limited – Data Protection Officer (DPO)
Contact Address: 1054 Sukhumvit 66/1, Phrakhanong Tai Sub-district, Phrakhanong District, Bangkok 10260
Phone Number: 02 856 2000
Email: dpo@jaspal.co.th
Or
Human Resource Department, Jaspal Public Company Limited
Email: hrpdpa@jaspal.co.th
You hereby acknowledge and agree that this Privacy Notice is governed by and construed in accordance with the laws of Thailand, and that the courts of Thailand have jurisdiction over any disputes that may arise.
Effective Date: 6 September 2024
