1. General
This Privacy Notice (“Privacy Notice”) relates to the collection, storage, use and disclosure of your personal data by Eastern Pacific Shipping Pte. Ltd., Eastern Pacific Shipping (UK) Limited, Ventnor Navigation Inc. and their respective affiliates, subsidiaries and shareholders (each and together, “we”, "our" or “us”) throughout the recruitment process including personal data provided by or through a manning office or via one of our third party manning agents.
We act as a controller for personal data collected for recruitment purposes.
This Privacy Notice also sets out your rights and who you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment as a seafarer, and our optional recruiting programs and events. It does not apply to our employees, contractors or counterparties, or other personal data that we collect for other purposes.
2. Information we collect
This information will include your personal data, which means information that can be used to identify you. This may include but is not limited to your contact information, such as your home address and contact details (including your mobile telephone number), your date of birth, your educational and professional qualifications, your right to work, visa status, employment status, and any other information about you that you disclose to us or that we gather during the recruitment process.
The personal data that we collect about you may also include special categories of personal data, such as information about your racial or ethnic origin, criminal or alleged criminal offences, or your health and lifestyle, where applicable to the recruitment process including where necessary to accommodate any disability needs.
If you fail to provide us with this information, or you object to us processing such information, the consequences are that we may be prevented from progressing your application.
3. How we collect information about you
We collect your personal data when you submit a job application by any method including by submitting an employment application to us directly or via one of our manning offices.
In considering your application we may also obtain information from third party sources, including any referees that you specify and publicly available sources.
4. What we do with the information we gather
We may use the information and opinions collected through the recruitment process (including but not limited to setting up and conducting interviews and tests and evaluating and assessing the results) for the following purposes:
- to consider and process any application that you make for any particular job with us including to identify and contact you;
- to determine whether you have the professional skills, expertise and experience for the position applied for;
- if you are offered a position with us, to verify the personal data provided including your identity, address, right to work, employment history and academic background and other background screening purposes including, where allowed by law, criminal record checks, searches with a credit reference agency and sanctions screening checks;
- to assist in the administration our recruitment programme, recruitment campaign planning, and compliance with related internal policies;
- to provide you with information about other job vacancies if you would like us to send you such notifications; and
- for statistical purposes.
If you are successful in the application process any information provided may form the basis of your personnel record with us and may be used for the purposes of administering your employment, benefits and training with the firm, ensuring your health and safety and to fulfil the firm's responsibilities as an employer. You will receive further information about such processing as applicable.
5. Legal basis for processing
We will be permitted to process your personal data in the ways we have described by relying on one or more of the following legal bases for processing your personal data:
- you have explicitly agreed to us processing your information for a specific reason or purpose;
- the processing is necessary to perform an agreement we already have with you or to take steps to enter into an agreement with you (e.g. a contract of employment); and/or
- the processing is necessary for the purposes of a legitimate interest pursued by us, which might be to protect our business interests; or to evaluate, develop or improve our services.
In relation to any processing of special categories of personal data, we will generally rely on your specific consent in order to process such data. It may be necessary for us to use certain personal data (such as that relating to alleged offences) in order to comply with our legal obligations.
6. Sharing Your Information
In order to consider any application that you make to us including by submitting an application form via a manning office or through a third party recruitment agency or via the EPS website, we may transfer your personal information to our affiliates and our principals in countries outside the European Economic Area (“EEA”) and to third party service providers assisting us with the recruitment process.
You should be aware that in territories outside the EEA, data privacy laws and practices are likely to be different and may be less stringent than those within the EEA. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations.
We may also share your personal information with:
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
Except as indicated above, your details will be accessible only by our authorised personnel and will not be disclosed to any third party. The information we hold is not traded with any external bodies or organisations and is not used for marketing purposes.
7. How long do we retain your personal data
If your application for employment is unsuccessful then we may continue to hold information and opinions about you and your applications after any application process is complete, in case we need to consult it in the future if you make another application or become our employee, if a dispute arises about an application that you have made or in order to contact you if potentially suitable job opportunities become available in the future.
We will delete or anonymise your information after 6 years or sooner, if we no longer need it, although we may continue to hold purely statistical information which does not identify you.
8. Your rights
You should note that you have the right to access, modify or delete any information concerning your personal profile in compliance with applicable data protection legislation. To access or correct any inaccuracies in your personal details you may do so by contacting the Data Protection Officer, Olga Venzhina, at pdpcompliance@epshipping.com.sg
Where you have consented to our processing of your personal data (including special categories of personal data) you may withdraw your consent at any time, by contacting the Data Protection Officer, Olga Venzhina, at pdpcompliance@epshipping.com.sg to request that we stop using your personal data. Please note that in certain circumstances it may be still lawful for us to continue processing your personal data even where you have withdrawn your consent if such processing is required and is in accordance with one of the other legal bases described above.
If at any stage you would like to withdraw an application, or if you wish to raise a complaint about how we are using your personal data or you do not wish us to contact you in relation to future employment opportunities, please let us know by sending an email to the Data Protection Officer, Olga Venzhina, at pdpcompliance@epshipping.com.sg
If you have any concerns about our use of your information, you also have the right to make a complaint to the relevant data protection authorities which regulate and supervise the use of personal data in your country.
