Privacy Notice

Entity Commercial Name: Protective Intelligence Network
Entity Registered Name: FAH Intelligence Pte. Ltd.

This document represents a FAH Intelligence Pte Ltd external statement made to a data subject that describes how the company collects, uses, retains and discloses personal information. This privacy notice is sometimes referred to as a privacy statement, a fair processing statement.

About FAH Intelligence Pte Ltd

As provider of trusted answers, FAH intelligence Pte Ltd has been committed to honoring privacy and keeping personal data safe. The new European General Data Protection Regulation (GDPR), which went into effect on May 2018, or the Singaporean Personal Data, Protection Act (PDPA) are consistent with these values.

This privacy notice describes how FAH Intelligence Pte Ltd collect, store, use and protect personal information.

FAH Intelligence is a security agency that provide security products in the frame of protective security and intelligence disciplines. Most common products are travel security reports, threat assessments, due diligences and background checks.

The company is registered under Singapore Laws.

FAH Intelligence background check verifications

FAH Intelligence in the frame of background checks activities obtains information for the purposes of background screening on an individual or entity only upon the request of a company or organization who has a permissible purpose - under the Singaporean Personal Data Protection Act (PDPA), the European General Data Protection Regulation (GDPR), and/or others privacy laws and regulations - to request such information on that person and entity for specific lawful and permissible purposes.

For example, in cases of employment practices or specific internal investigations as a permissible purpose, FAH intelligence requires the requesting company or organization to certify to FAH Intelligence that it has obtained the written consent of the Person of Interest (POI – the person subject of verifications) to access related information, before FAH intelligence can supply the requested information, unless specific exception considered under PDPA, GDPR, and privacy laws regulation apply. The requesting company, or organization, or entity, must submit to reasonable audits by FAH Intelligence to confirm that it is, in fact, obtaining such consents.

To note, FAH Intelligence Pte Ltd does not maintain any database of Person of Interest or other entities, nor use or sell the collected information for commercial advertising purposes.

Any information gathered on any Person of Interest may only be provided to the end user authorized by the Person of Interest to receive the information. FAH Intelligence does not share, sell or distribute POI information with or to any third-party other than the requesting party thereof. Any Person of Interest, upon proper identification, has the right under the PDPA or the GDPR to request the originating requesting company or organization, and consequently FAH Intelligence, to be furnished any and all information it may have been collected on him/her. The person of interest has the right to dispute the accuracy or completeness of any information contained in the POI’s report or file.

Access to confidential POI’s information is limited within FAH Intelligence to those who have a need to know the information, such as:

those obtaining and transmitting information on the Person of Interest,
those dealing with a Person of Interest request for information,
and those handling the POI – subject of verification’s activity - disputes.
Employees are prohibited from “browsing” files or databases linked to verifications without a business justification.
FAH Intelligence identifies each end user who is requesting information on a POI. End users are verified as an authorized user prior to FAH Intelligence releasing any consumer information.

Collected information or any information resulting of external interaction containing private data is duly secured:

Access to FAH Intelligence office is secured by h24 security guarding services.
Fah Intelligence office has a secure door closed by PIN coded electromagnetic lock, a second mechanical door locks, and an internal security CCTV system.
The Security CCTV system is accessible via web. CCTV prompt information on office access, and computer access.
Security Facial Recognition System for Personnel.
Access to FAH Intelligence’s computer terminals, file cabinets, trash bins, desktops, etc. are secure from unauthorized access.
Any backup data is maintained in an encrypted form using state of the art technology.
Destruction of POI’s information follows regulation’s requirements that the information will be unreadable upon disposal.

All questions and concerns regarding this privacy statement should be directed to us at: FAH Intelligence Pte Ltd, Compliance and Privacy Officer, Email: POC@networkpi.net

Why FAH Intelligence uses personal data information during background checks activities

Our primary purpose in collecting personal information is to provide the requesting company or organization with a realistic account of facts that may support security awareness specifically required for hiring personnel, or for sensitive investigative purposes.

In general, requested verifications from companies and organizations are commonly related to:

Making a decision about recruitment or appointment.
Providing contractual benefits.
Administering the contract the company or organization have entered into with a person
Business management and planning, including accounting and auditing.
Conducting performance reviews, managing performance and determining performance requirements.
Making decisions about salary reviews and compensation.
To assess the suitability for potential roles with clients.
To contact a person about a potential role with a client. To contact a person about your service requirements.
To propose a candidate for engagement (either on a temporary or permanent employment basis)
Assessing a person’s qualifications for a particular job or task, including decisions about promotions.
Gathering evidence on employees for possible grievance or disciplinary hearings.
Making decisions about an employee continued employment or engagement.
Making arrangements for the termination of working relationship.
Education, training and development requirements.
Dealing with legal disputes involving an employee, or workers and contractors, including accidents at work.
To prevent fraud.
To monitor the use of internal information and communication systems to ensure compliance with a company IT policy.
To ensure network and information security, including preventing unauthorised access to a company’s computer and electronic communications systems and preventing malicious software distribution.
To conduct data analytics studies to review and better understand employee retention and attrition rates.
To compare information for accuracy and verify it with third parties.
To verify business activity in case of due diligences.
To abide business regulatory requirements and commercial imperatives.
To prevent potentially prohibited or illegal activities.
To prevent criminal acts in the frame of the organization/company premises.

On a general point of view, the vetting activity is also aimed to reduce the possibility of so-called “insider threat” induced by the presence of criminals and terrorists or person linked in some ways to them, or again persons that expose - during the vetting process – an online behavior that is considered very negative under a reputational or security evaluation. The final intention aims to enhance “security knowledge” against applicants or Person of Interest lists, and never in order to be used for commercial advertising reason.

How data is collected

Data is collected in different forms such as:

Open Sources accessed and retrievable online.
Open Sources accessed in person (Public registers offices, Libraries, Government offices, Law Enforcement offices, Courts)
Organizations and Companies websites.
Personal data which is publicly available on websites such as jobs boards, LinkedIn, or similar recruitment-related websites.
Law Enforcement Agencies public websites.
Third-party applications which source their data from publicly-available websites. (The indicated third-parties have PDPA, GDPR and/or other privacy laws and regulations policies in place.)

What kind of data FAH Intelligence will possibly check during background checks activities:

Travel Document: Standard Travel Documents Machine Readable Zone verification whenever provided by the POI and the requesting company or organization in order to accomplish a very basic security verification on the travel document.
Residency – Standard residency checks whenever is the case in the case of hiring or contracted positions in order to check the candidate’s address.
Professional qualifications – Standard checks of professional qualifications relevant to the POI’s role as candidate or worker.
Education and Credentials Verification: Education and credential verification validate university postgraduate and graduate degrees, technical trainings, secondary school qualifications, and specific certifications or professional licenses pertaining to a job, on the basis of the consent of the applicant and the legitimate interest of the employer.
Information about Criminal convictions: According to Article 10 of the GDPR (Processing of personal data relating to criminal convictions and offences) processing of personal data relating to criminal convictions and offences or related security measures based on Article 6(1) shall be carried out only under the control of official authority or when the processing is authorised by EU or Member State law providing for appropriate safeguards for the rights and freedoms of data subjects. Hence, FAH Intelligence may only use information relating to criminal convictions where the law allows such verification. This will be usually the case where such processing is necessary to carry out obligations and provided it is done in line with data protection requirements. Information about criminal convictions will be only collected if it is appropriate given the nature of the role and where it is consented by the national laws, therefore legally able to do so.
Employment – Standard employment referencing. After consent, employment and activity verifications ensure the accuracy of the employment and activity information listed on a job application and/or CV.
Directorship – Due diligence checks to identify past, present, and disqualified directorships; and Secretaryships held, on the basis of the legitimate interest of the employer to ascertain if there is any potential conflict of interest.
Financial probity – A review of all publicly held financial information about the candidate. The check is performed to identify any registered debts, previous or existing Country Court Judgements, bankruptcies etc. to safeguard against any possible improper conduct.
Social Media: A concrete ground is required for this processing, such as legitimate interest or requester acquired consent. In this context, prior to the inspection of a social media profile or information publicly available on the internet, the requesting company is prompt by FAH Intelligence to request specific consent. FAH Intelligence will uniquely take into account social media profile or internet information that may relate to business purposes. Derogatory comments and expressions of criminal nature or criminal support will be underlined.
Adverse Media: To identify any adverse media coverage the candidate has received from industry journals, court papers, local and international newspapers etc. can include, but not limited to: fraud, violence, weapons, drugs, criminal damage, terrorism crime, sabotage, cybercrime, identity fraud etc. and any negative publicity that would constitute potential risk to the reputation of the company or the organization.

What kind of data FAH Intelligence will collect during security training activities

In order to provide training to people on security matters, basic information is collected for the purposes of communication and temporary administrative matters only.

The Data collected are:

Participant’s Name and Surname.
Participant’s Qualification/ Profession.
Participant’s Professional background.
Participant’s Email address
Participant’s Telephone Number

Moreover, please note that:

FAH Intelligence employees are prohibited from “browsing” files or databases linked to trainees lists without a business justification.
Access to FAH Intelligence office is secured by h24 security guarding services.
Fah Intelligence office has a secure door closed by PIN coded electromagnetic lock, a second mechanical door locks, and a security CCTV system.
Access to FAH Intelligence’s computer terminals, file cabinets, fax machines, trash bins, desktops, etc. are secure from unauthorized access.
Any backup data is maintained in an encrypted form using state of the art technology.
Destruction of POI’s information follows regulation’s requirements that the information will be unreadable upon disposal.
The data collected is not used for commercial advertising reason, nor it is sold to other security or training companies.

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FAH Intelligence Pte Ltd may revise this privacy notice from time to time. If we make any material changes, we will notify you by posting a prominent announcement on the website.

FAH Intelligence Pte Ltd.
Havelock II, 2 Havelock Rd,
059763, Singapore

This page was last updated on 25th May, 2018.