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BLACKBOX EXECUTIVE - PRIVACY POLICY

Last updated: October 2026

 

1.  WHO WE ARE

BlackBox Executive is a trading name of BlackBox Compliance Pte. Ltd. ("BlackBox Executive", "we", "our" or "us"), an executive search and recruitment firm incorporated in Singapore and licensed by the Ministry of Manpower as an employment agency (EA Licence No. 18S9482).  This policy explains how we collect, use, disclose and protect your personal data and the rights you have over it.

We comply with Singapore's Personal Data Protection Act 2012 (PDPA).  Where we handle the personal data of individuals in the United Kingdom, for example candidates relocating from the UK to Singapore, we also comply with the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018.  For UK purposes, BlackBox Compliance Pte. Ltd. is the data controller.

 

2.  OUR DATA PROTECTION OFFICER

If you have any questions about this policy or how we handle your personal data, please contact our Data Protection Officer:

Data Protection Officer, BlackBox Compliance Pte. Ltd. (trading as BlackBox Executive)

8 Boon Lay Way, #04-15 Tradehub 21, Singapore 609964

Email: paulevans@blackboxcompliance.com

 

3.  WHOSE DATA WE COLLECT

We collect personal data about candidates (prospective and placed), client contacts, referees, suppliers and visitors to our website.

 

4.  WHAT PERSONAL DATA WE COLLECT

Depending on how you deal with us, this may include:

  • your name, contact details and professional profiles (for example LinkedIn);

  • your CV, employment history, qualifications, skills and references;

  • current and expected remuneration and notice period;

  • your nationality, right to work and work pass or visa details where needed for a placement;

  • notes from our conversations and interviews with you;

  • information about your use of our website, such as your IP address and cookies.

We will only collect NRIC or passport numbers where required by law or where it is necessary to verify your identity to a high degree of accuracy, for example for a work pass application.  We do not ask for sensitive information such as health details unless you choose to share it or it is required by law.

 

5.  HOW WE COLLECT IT

We collect personal data directly from you (for example when you send us your CV, speak with us or contact us through our website), from publicly available sources such as LinkedIn, company websites and professional directories and from third parties such as referees, our clients and people who recommend you to us.

 

6.  WHY WE USE YOUR PERSONAL DATA

We use your personal data to:

  • provide our executive search and recruitment services, including assessing your suitability for roles;

  • introduce you to clients and arrange interviews (we will always ask you before sending your CV to a client);

  • carry out reference and background checks where required for a role;

  • support work pass and relocation arrangements following a placement;

  • keep in touch with you about relevant opportunities and market insight;

  • manage our relationship with clients and suppliers;

  • meet our legal and regulatory obligations, including those under the Employment Agencies Act 1958;

  • run and improve our website.

 

7.  CONSENT AND LEGAL BASIS

Singapore: we collect, use and disclose your personal data with your consent, including consent that is deemed under the PDPA, or where an exception under the PDPA applies, such as our legitimate interests or business improvement purposes.

United Kingdom: where the UK GDPR applies, we rely on our legitimate interests in providing recruitment services, the performance of a contract with you, compliance with legal obligations and, where needed, your consent.

You may withdraw your consent at any time by contacting our Data Protection Officer.  We will tell you what the likely consequences are (for example, that we may no longer be able to represent you for roles) and will act on your request within a reasonable time.

 

8.  WHO WE SHARE YOUR DATA WITH

We may share your personal data with:

  • clients who are considering you for a role, with your agreement;

  • referees and background screening providers;

  • our service providers, including Zoho Recruit (Zoho Corporation), which hosts our candidate database, and our email, IT and cloud storage providers;

  • professional advisers such as lawyers and accountants;

  • government agencies, regulators or law enforcement where we are required or permitted by law.

We do not sell your personal data.

 

9.  TRANSFERS OUTSIDE SINGAPORE AND THE UK

Our service providers may store personal data on servers outside Singapore, and we may introduce you to clients in other countries.  When we transfer personal data out of Singapore, we take steps to make sure it receives a standard of protection comparable to the PDPA, for example through contractual safeguards.

Where personal data is transferred out of the UK, we use appropriate safeguards recognised under UK law, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

 

10.  HOW WE PROTECT YOUR DATA

We make reasonable security arrangements to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal and loss.  These include access controls, secure systems and choosing service providers with appropriate security standards.  No method of transmission over the internet is completely secure, so we cannot guarantee absolute security.

 

11.  HOW LONG WE KEEP YOUR DATA

We keep personal data only for as long as it is needed for the purposes it was collected for, or as required for legal or business reasons.  We review our records regularly and securely delete or anonymise personal data that we no longer need.

 

12.  YOUR RIGHTS

Under the PDPA, you can ask to access the personal data we hold about you, ask how it has been used or disclosed in the past year, ask us to correct it and withdraw your consent.  We will respond to access and correction requests within 30 days, or let you know if we need more time.  We may charge a reasonable fee for an access request and will tell you the amount in advance.

If the UK GDPR applies to you, you also have the right to request erasure, restrict or object to processing and request a copy of your data in a portable format.

To make a request, please contact our Data Protection Officer.  We may need to verify your identity first.

 

13.  COMPLAINTS

We would like the chance to resolve any concerns first, so please contact us.  You may also complain to the Personal Data Protection Commission in Singapore (www.pdpc.gov.sg) or, if the UK GDPR applies to you, the Information Commissioner's Office in the UK (www.ico.org.uk).

 

14.  DATA BREACHES

If a data breach occurs, we will assess it promptly.  Where it is notifiable under the PDPA, we will notify the Personal Data Protection Commission within 3 calendar days of our assessment and inform affected individuals where required.  Where UK data is affected, we will notify the Information Commissioner's Office within 72 hours where required.

 

15.  MARKETING AND THE DO NOT CALL REGISTRY

We may send you news about our services or relevant opportunities.  You can opt out at any time by replying to us or using the unsubscribe link.  We will not send marketing messages to Singapore telephone numbers registered with the Do Not Call Registry unless you have given us clear consent.

 

16.  COOKIES

Our website uses cookies to make it work properly and to understand how visitors use it.  You can set your browser to refuse cookies, although some parts of the site may not then work as intended.

 

17.  OTHER WEBSITES

Our website may link to other websites.  We are not responsible for their privacy practices, so please read their privacy policies.

 

18.  CHANGES TO THIS POLICY

We may update this policy from time to time.  The latest version will always be on this page.

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