Statement of Policy
Savills (Thailand) Limited (“Savills”, “we”, “us” or “our”) respects personal data privacy and is committed to implement and comply with the data protection principles and provisions under the Personal Data Protection Act (“PDPA”). Any reference to “you” refers to anyone whose personal data Savills processes.
Statement of Practices
1. Savills collects and holds the following categories of personal data:
Customer records which include personal data collected in the course of providing our services, processing your request, handling transactions, complaints and enquiries, research and marketing etc. Customers personal data such as full name, address, phone number, email address, bank account details, passport, or an identification card.
Employment-related records which include data on job applications, personal particulars, education and qualifications, employment history, salary and allowances, participation in Provident Fund, social security, medical benefits, leave records, record of attendance, appraisal reports, conduct and discipline, etc.; sensitive data such as biometric data (fingerprint data), medical information, criminal history, disability information.
General administrative records which include personal data collected in connection with the office administration functions, records containing information supplied by data subjects and collected in connection with the handling of enquiries and complaints made to Savills, etc.
Main Purposes of Keeping Personal Data
2. The purpose of collecting, using, or disclosing the personal data are follows:
Agency Services
• For providing our services, negotiating, listing, and fulfilling your requests or perform contract obligations as agent to let or sell or manage your property;
• For carrying out various transactions related to our services;
• For conducting identity check or due diligent to comply with our internal policies or any applicable laws and regulations;
• For promoting and managing the relationship with you;
• For contacting or informing news, benefits, or market updates to you or conduct any marketing activities;
• For any reference and handling of enquiries and complaints;
• For carrying out actions as required by law, government agencies, cooperation with law enforcement officers, government agencies, regulatory authorities, and/or court orders;
• For the exercise of legal claims, exercising legal rights, establishing, preserving, or extinguishing legal rights.
Property Management Services
• For providing our services or performing contract obligations under the property management agreement or any applicable laws and regulations;
• For contacting, communicating, and managing the relationship with you;
• For any reference or handling of enquiries and complaints;
• For complying with our procurement policy and procedure;
• For promoting or informing news, benefits, or market updates to you or conduct any marketing activities;
• To carry out actions as required by law, government agencies, cooperation with law enforcement officers, government agencies, regulatory authorities, and/or court orders.
• For the exercise of legal claims, exercising legal rights, establishing, preserving, or extinguishing legal rights.
Employment and Human Resource Management
• To carry out the company's job application and employment procedures.
• For certification and verification of information, documents, and for contacts.
• To evaluate the suitability of applicants, make hiring decisions, determine salary, and provide other information for employment contracts.
• To assess any potential conflicts of interest between you and any other person connected to Savills.
• To carry out or take any action regarding employment agreements between Savills and you.
• To provide resources to facilitate your work.
• To promote, train, and practice skills and expertise necessary for the performance of your duties or operations related to your role.
• For recruiting or allocating welfare operations benefits such as Social Security and Provident Fund.
• To carry out various activities of the company to promote and manage the relationship between Savills and you.
• For registration operations, accounting preparation, data analysis, checking the correctness of information, making records for reference, or exercising legal rights.
• To communicate, inform, and/or receive various information from Savills or updates on changes occurring within the company.
• To carry out an account audit and inspection in the event of corruption or disciplinary offenses.
• To carry out actions as required by law, government agencies, cooperation with law enforcement officers, government agencies, regulatory authorities, and/or court orders.
• For the exercise of legal claims, exercising legal rights, establishing, preserving, or extinguishing legal rights.
Savills collects, uses and/or discloses personal data of you above based on the following legal bases as follows:
(1) To carry out the contract or any action related to the agreement between Savills and you.
(2) Legal duties and responsibilities: this involves actions to comply with the Company's legal obligations and responsibilities.
(3) Legitimate interest: this involves actions for the rightful benefit of the Company and the rightful benefit of third parties.
(4) Vital interests: this involves actions to prevent or stop danger to the life, body, or health of a person.
(5) Public interest: this involves actions performed for the public benefit or for the performance of a government official's duties.
Resulting of not providing your personal data that we request
We need some of your personal data to perform the services you have requested from us.
We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to fulfil our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
3. Who Savills Shares Your Personal Data
The company may disclose or transfer your personal information to several categories of entities:
Group of affiliated companies: Savills may share or transfer your personal data with its group of affiliated companies or subsidiaries as Savills may collaborate or share personnel, services, and systems, including website-related services and systems within the purposes outlined in the privacy policy.
Service providers and business partners: Savills may transfer your personal data to third-party service providers and business partners. These could include, but are not limited to Internet, software, and information technology support service providers. Employment agents and personnel service providers.
Third parties as required by law: Savills may be obligated to disclose or forward your personal information to comply with legal requirements or regulations. This could include orders from law enforcement agencies, courts, government agencies, or other third parties. Such disclosures may be necessary to comply with laws, protect the rights of the Savills or others, ensure personal safety, or investigate and prevent illegal activities or security issues.
4. Practices of Personal Data Handling
The practices at (a) to (e) below are implemented to ensure that personal data held by Savills is handled in accordance with the data protection principles enshrined in the PDPA.
(a) Collection of personal data
When collecting personal data, Savills will satisfy the following:
ithe purposes for which the data is collected are lawful and directly related to a function or activity of Savills;
iithe manner of collection is lawful and fair in the circumstances of the case; and
iiithe personal data collected is necessary but not excessive for the purpose(s) for which it is collected.
When Savills collects personal data from an individual, the individual will be provided with a Personal Information Collection Statement on or before the collection in an appropriate format and manner. Practicable steps will be taken to ensure that –
ithe data subject is informed of whether it is obligatory or voluntary for him/her to supply the data and, if obligatory, the consequences for him/her if he/she fails to do so; and
ithe data subject is explicitly informed of the purpose for which his/her personal data is to be used, the classes of persons to whom the data may be transferred or disclosed, the rights of the data subject to request access to and correction of the data, and the contact details of the individual to whom any such request may be made.
(b) Accuracy and retention of personal data
Personal data collected and maintained by Savills shall be as accurate, complete, and up-to-date as is necessary for the purpose for which it is to be used.
Savills maintains a personal data inventory, which contains the kinds of personal data that Savills holds; the purposes for which the personal data is collected, used and disclosed; and how the personal data is stored. The personal data inventory will be reviewed on an annual basis to ensure that it is accurate and up-to-date.
Personal data will not be kept longer than necessary for the fulfilment of the purpose for which the data is collected or used. Personal data that is no longer required should be erased unless such erasure of personal data is prohibited under any law or it is in the public interest for the data not to be erased. Should there be a need to retain the personal data for statistical purposes, such data will be anonymised so that the individuals concerned can no longer be identified.
A destruction exercise on records containing personal data will be conducted as and when necessary and in accordance with Savills records management guidelines and procedures. Destruction of paper records would be carried out by irreversible means and electronic records would be cleared or destroyed from storage media before disposal by means of sanitisation or physical destruction.
(c) Use of personal data
All personal data collected will be used only for purposes, which are directly related to the discharge of Savills’ duties and responsibilities. Personal data collected may be transferred to third parties during the discharge of Savills’ functions when necessary. Relevant personal data may also be disclosed to other entities which are authorised to receive information for the purposes of law enforcement, prosecution or review of decisions. Data subjects would be informed of the possible transferees of their personal data when their personal data is collected.
If personal data is to be used for a purpose other than the purposes for which the data is collected, express prior consent preferred in writing would be sought from the data subject concerned. In seeking the data subject’s consent, all practicable steps would be taken to ensure that (i) information provided to the data subject is clearly understandable and readable; and (ii) the data subject is informed that he/she is entitled to withhold his/her consent or withdraw his/her consent subsequently by giving notice in writing.
(d) Security of personal data
Savills observes strictly relevant security standards and regulations. Security arrangements will also be reviewed regularly to ensure that personal data is protected against loss and unauthorised or accidental access, use, disclosure, modification and erasure. The security arrangements adopted include but not limited to the following:
(i) restriction of access to personal data on a “need-to-know” basis;
(ii) regular review and enhancement of security measures for protection of personal data in the servers, user computers, transmission of electronic messages, etc.;
(iii) regular change of passwords for IT facilities, accounting and personnel systems, etc.;
(iv) encryption of all backup storage devices that are to be transported to offsite storage;
(v) limited staff access rights to office areas storing confidential information; and
(vi) provision of clear guidelines to staff as to the types of data that may or may not be disclosed to a phone enquirer and implementation of appropriate identity verification procedures to confirm the enquirer’s identity.
(e) Transparency of the personal data policy and practices
privacy policy and practices can be found on Savills website.
5. For how long we keep your personal data
The period for which we will keep your personal data will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in case of a legal claim.
6. International Data Transfer
1. Your Personal Data may be transferred to, and processed in, countries other than Thailand. These countries may have data protection laws that are different to the laws of Thailand (and, in some cases, may not offer the same protection).
2. Our Website servers are located at Amazon Web Services all over the world, and our group companies, affiliated companies and third-party service providers operate globally. This means that when we collect your Personal Data, we may process it in any of these countries.
3. However, we take steps to safeguard your Personal Data in accordance with this Privacy Policy Statement. Further details about the protection given to your Personal Data can be provided upon request by contacting us using the details herein.
7. Your rights in relation to your personal data
You have a number of rights in relation to your personal data, these include the right to:
• Right to withdraw - Withdraw your consent at any time, provided that there is no other legal ground for Savills to continue with the processing of your personal data;
• Right to be informed - Be informed about how we use your personal data, why we collect your personal data, the consequences if you refuse to provide your personal data, how long we keep your personal data, and the category of the third party we may disclose your personal data to;
• Right to access and have a copy - Obtain access to your personal data that we hold and request a copy;
• Right to rectify - Request that your personal data is corrected if you believe it is incorrect, incomplete, or inaccurate;
• Right to be forgotten - Request that we erase or de-identify your personal data;
• Right to be restrict - Ask us to restrict our data processing activities where you consider that personal data is inaccurate, our processing of your personal data is unlawful etc.
• Right to data portability - Receive your personal data in a commonly used and machine-readable format, and to have your personal data in said format transmitted to another organization;
• Right to object - Object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful;
• Right to complain - Lodge complaints to the competent authority.
If you would like to exercise any of your rights, please contact our Data Protection Officer at [email protected].
When handling a data rights request, Savills will check the identity of the requester to ensure that he/she is the person legally entitled to exercise the rights.
Savills may impose a fee for the direct and necessary cost of complying with a data rights request. Savills will clearly inform the requestor the amount to be charged.
8. Incident Reporting and Breach Handling
A mechanism is set up for incident reporting and breach handling in case there is loss or leakage of personal data, or there is a reason to believe that the personal data held by Savills has been compromised.
9. Ongoing Monitoring and Review
Savills will keep the Privacy Policy and Practices under regular review and reserve the right to revise the Privacy Policy from time to time. Officers responsible for handling personal data will attend relevant training courses and keep up to date with personal data policies.
10. Complaints and Contact Details
Complaints
If you have any complaints about the way, we use your personal information please contact our Data Protection Officer at [email protected] who will try to resolve the issue.
Contact details
If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by sending an email to [email protected] or writing to our Data Protection Officer at Savills (Thailand) Limited, 26th Floor, Abdulrahim Place, 990 Rama 4 Road, Silom, Bangrak, Bangkok 10500.
11. The use of cookies by Savills
What is a cookie?
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What cookies do Savills use?
The table below lists the cookies used by this website and provides a description of how each cookie works, clicking the '+' symbol will expand the box to give further explanation on each cookie. Where further information about a cookie exists on an external website a link has been provided under 'More information'.
How do I restrict or delete cookies?
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