How White Gate Partners collects, uses, discloses, stores and protects personal data.
This Privacy Policy explains how White Gate Partners Pte. Ltd. (“White Gate Partners”, “WGP”, “we”, “our” or “us”) collects, uses, discloses, stores and protects personal data when individuals visit our website, contact us, or engage with our executive search, specialist recruitment, talent solutions and related consulting services.
This Policy is primarily governed by the Personal Data Protection Act 2012 of Singapore (“PDPA”). Where the laws of another jurisdiction apply to a particular processing activity, we will take reasonable steps to comply with the applicable requirements.
This Policy should be read together with the Candidate Privacy Notice included in Part B, which provides additional information about how we handle candidate and job applicant data.
White Gate Partners is a Singapore-based executive search, specialist recruitment and talent solutions firm. This Policy applies to personal data in our possession or under our control, including personal data processed for us by service providers and other third parties.
It applies to candidates, job applicants, clients, prospective clients, business contacts, referral partners, independent recruiters, consultants, website visitors and other individuals who interact with us.
Depending on your relationship with us, we may collect the following categories of personal data:
We do not intentionally request sensitive personal data unless it is relevant and reasonably necessary for a stated purpose. Where you choose to provide information such as health or accessibility requirements, we will handle it with appropriate care.
We may collect personal data:
Where we obtain your personal data from another source, we will use it only for reasonable purposes connected with our services and in accordance with applicable law.
We may collect, use and disclose personal data for purposes including:
Automated decision-making and profiling. WGP does not currently make significant recruitment decisions solely through automated processing without human involvement. We may use technology-assisted, including AI-assisted, search, matching, screening or psychometric assessment tools to support our consultants; where such tools are used, their outputs are reviewed by an appropriately authorised person.
We generally collect, use and disclose personal data with your consent, which may be expressed or deemed from the circumstances. In particular, where permitted and the statutory conditions are met, WGP may rely on deemed consent by contractual necessity under section 15 of the PDPA, including where collection, use or disclosure is reasonably necessary to enter into or perform a contract with you, and deemed consent by notification under section 15A of the PDPA, including when sourcing relevant professional information from a third-party platform after notifying you of the purposes and giving you a reasonable opportunity to opt out. We may also rely on other exceptions or permitted grounds under the PDPA or other applicable law.
You may withdraw consent by contacting us. We will explain the likely consequences of withdrawal and will cease the relevant collection, use or disclosure within a reasonable period, subject to any legal or business grounds that permit or require continued processing.
We may disclose personal data, where reasonably necessary, to:
We do not sell personal data.
Because WGP supports regional and cross-border assignments and uses service providers that may operate internationally, personal data may be transferred, stored or processed outside Singapore.
Where personal data is transferred outside Singapore, we will use a permitted transfer mechanism and take steps to ensure the recipient provides a standard of protection comparable to that required under the PDPA. Depending on the circumstances, this may include written contractual arrangements requiring comparable protection, including standard data-transfer clauses; binding corporate rules or equivalent intra-group safeguards; transfer to a prescribed or otherwise recognised country or jurisdiction where applicable; or reliance on another statutory exception or permitted mechanism under the PDPA.
We implement reasonable administrative, physical and technical safeguards designed to protect personal data from unauthorised access, collection, use, disclosure, copying, modification, loss or disposal.
Security measures may include access controls, password protection, secure cloud services, device and account security, staff and contractor confidentiality requirements, and appropriate vendor management. No method of transmission or storage is completely secure, and absolute security cannot be guaranteed.
We retain personal data only for as long as it is reasonably required for the purposes for which it was collected, for an ongoing business or recruitment relationship, or to satisfy legal, contractual, accounting, regulatory, dispute-resolution or record-keeping requirements.
Candidate records are generally reviewed for deletion or anonymisation within two (2) years of our last meaningful interaction, unless there is an ongoing recruitment process, placement, contractual obligation, dispute, legal requirement or other legitimate business reason requiring longer retention.
Indicative retention periods include:
These periods are guidelines rather than fixed guarantees and may be extended where necessary, after which the data will be deleted, anonymised or securely disposed of.
Client, commercial, financial and placement records may be retained for a longer period where required for business, accounting, legal or regulatory purposes. When retention is no longer necessary, we will take reasonable steps to delete, anonymise or securely dispose of the data.
When you visit our website, our hosting, security and technology providers may automatically collect technical information such as IP address, browser type, device information, access time, referring page and website activity.
Our website may use the following cookie categories:
You may control cookies through your browser settings and, where provided, our cookie banner.
Subject to the PDPA and any applicable exceptions, you may:
To protect personal data, we may need to verify your identity and the scope of your request. We may charge a reasonable fee for an access request where permitted and will inform you of the fee in advance.
We will generally respond to access or correction requests within thirty (30) calendar days. If more time is required, we will inform you of the expected response timeframe.
We may send business updates, market insights, event invitations or other relevant communications where permitted. You may opt out of non-essential marketing communications at any time by using the unsubscribe method provided or contacting us at privacy@whitegatepartners.sg.
We may continue to send service, recruitment, contractual or administrative communications that are necessary for an existing relationship or transaction.
Before sending marketing messages to Singapore telephone numbers, including calls and text messages, WGP will check the Do Not Call Registry where required and comply with the applicable Do Not Call provisions in Part IX of the PDPA, including requirements relating to consent, identification and opt-out requests.
If you provide personal data relating to another individual, you confirm that you are authorised to provide it to us and have informed the individual of the purposes for which it may be used.
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties, and you should review their privacy notices separately.
We maintain procedures to assess and respond to suspected personal-data breaches. Where required by applicable law, we will notify the relevant authority and affected individuals of a notifiable breach within the prescribed timeframe.
We may update this Policy from time to time to reflect changes in our services, practices, technology or legal obligations. The revised version will be published with an updated “Last updated” date. Where a material change affects how we use personal data, we will provide additional notice or obtain consent where required.
Questions, requests, complaints or feedback relating to this Policy or your personal data may be directed to:
White Gate Partners Pte. Ltd.
privacy@whitegatepartners.sg
This Candidate Privacy Notice supplements the General Privacy Policy above and explains how White Gate Partners handles personal data relating to candidates, potential candidates and job applicants.
This Notice applies to individuals whom WGP considers, contacts, represents, assesses or introduces for employment, contract, consulting or other opportunities with our clients, as well as individuals applying to work or engage directly with WGP. WGP's services and recruitment processes are intended for individuals who are at least eighteen (18) years of age, and WGP does not knowingly collect personal data from minors. If we learn that personal data of a minor has been collected without appropriate authority, we will take reasonable steps to delete it.
Candidate personal data may include:
We may obtain candidate data:
We may use candidate data to:
Before presenting identifiable candidate information to a client, we will obtain your consent, unless you have already provided consent covering that presentation or an exception under the PDPA or other applicable law applies. We will limit any disclosure to information relevant to the opportunity and share it only with clients, authorised search or recruitment partners, service providers and other persons involved in the recruitment process, subject to confidentiality and purpose limitation.
For cross-border assignments, your data may be shared with a client or authorised partner outside Singapore. The overseas transfer safeguards described in the General Privacy Policy will apply.
You should provide information that is accurate, complete and not misleading, and inform us of material changes that may affect a recruitment process. You should not provide confidential information belonging to a current or former employer unless you are authorised to do so.
You may withdraw consent, request access to your personal data, or request correction of errors or omissions by contacting privacy@whitegatepartners.sg. Withdrawal may affect our ability to consider or represent you for opportunities, and we will explain the likely consequences before processing the request.
We will generally respond to access or correction requests within thirty (30) calendar days, subject to identity verification, applicable exceptions and any extension permitted by law.
Candidate records are generally reviewed for deletion or anonymisation within two (2) years of our last meaningful interaction. We may retain information for longer where there is an ongoing recruitment relationship, placement, guarantee period, contractual obligation, legal requirement, dispute or other legitimate business reason.
Questions, requests, complaints or feedback relating to this Notice or your personal data may be directed to:
White Gate Partners Pte. Ltd.
privacy@whitegatepartners.sg