What does this Recruitment Privacy Notice apply to?

This Recruitment Privacy Notice sets out the policy of Anscor Swire Ship Management Corporation (“ASSM”) in relation to the personal data we collect from individuals who apply for any employment, job or internship with ASSM. In this policy, ASSM and all its affiliates are set out in our website.
As well as this Recruitment Privacy Notice, local privacy notices may vary among the countries in which our principals operates to reflect local practices and legal requirements and is subject at all times to applicable law.
If in the course of or prior to your job application with us, you may visit our website to learn more about us, please also refer to our Privacy Notice for our Website Users to learn more about the information we collect through your use of our website.
This Recruitment Privacy Notice explains what personal data we collect from you, for which purposes we collect and use such personal data, how long we retain the personal data, how to access and update your personal data and how to contact us for further information.

Who is responsible for your personal information?

As part of any recruitment process, Anscor Swire Ship Management Corporation (“ASSM”) collects and processes personal data relating to job applicants. ASSM is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

Unless otherwise informed to you or set out in the job portal on our Site, Anscor Swire Ship Management Corporation (“ASSM”), a company registered in the Philippines with its business address at G/F Two-Ecom Center (Tower B) Harbor Drive corner Bayshore Ave. Mall of Asia Complex Pasay City 1300, is responsible for processing your personal data on behalf of itself or the relevant company within our principals’ group to which you are applying for a job. 

What information do we collect from you and for what purposes do we use such information:

ASSM collects a range of information about you. This includes:

  • Your name, address and contact details, including email address and telephone number;
  • Details of your qualifications, skills, experience and employment history;
  • Information about your current level of remuneration, including benefit entitlements;
  • Whether or not you have a disability for which ASSM needs to make reasonable adjustments during the recruitment process.

ASSM may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

We need to process data for various reasons:

a. To enter into a contract with you including the need for its processing;

b. To ensure we are complying with its legal obligations e.g.: mandatory background check; etc.

c. May process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics;

d. If your application is unsuccessful, ASSM may keep your personal data on file subject to standard retention period in case there are future employment opportunities for which you may be suited.

What personal data do we collect?
Legal basis and purpose for processing the data?
Personal information such as: Your name, address and contact details date of birth, marital status, place of residence Prior work experience information such as:
  CV, employment history, reference information and/or information received from background checks (where applicable). Such information may be provided to us by third parties e.g. recruiters. Professional qualifications and certificates. Education history and transcripts. Information from interviews.  
Special categories of data (“sensitive personal data”) such as: Health data – while we do not generally collect your health data for recruitment purposes, where required or permitted by local law to assess your fitness to work, we will process your health data strictly for such purpose only.   Information regarding nationality, racial or ethnic origin – such information may be processed in order to ensure equal employment opportunities and fair employment practices as permitted or required by local law. Sensitive personal data are processed only as strictly required and as permitted or required by local law.   
Our legal basis for processing your personal data could be any of or a combination of the following: To take steps at your request prior to entering into a contract with you. where necessary for the purposes of the legitimate interests pursued by the relevant company within our principals’ group, where we have considered these are not overridden by your rights.  Such legitimate interests include the following: To verify your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job. To comply with our principals’ own internal policies such as equal opportunity, modern slavery and human trafficking policy where necessary for us to comply with our legal obligations or to enforce or defend our legal rights. Our legal obligations include compliance with equal employment opportunities, fair employment practices, minimum legal working age, local content requirements under applicable law. (only if legally required) in accordance with the purposes for which you have granted your explicit consent. In cases where we process your personal data based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of our processing of your data prior to your withdrawal of consent.

Who do we share your information with?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the Operations area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with prospective principals or employers to obtain necessary background checks or where we have your explicit consent to do so for the particular purposes you have consented to.

Your personal data is processed only for the purposes above and may be shared with third parties in the following circumstances: 

a. with other companies within our principals’ group; 

b. with our authorised third party service providers who process personal data on our behalf, including to carry out reference and background checks on our behalf; 

c. referees indicated in your application or during your interview for the purposes of carrying our reference checks; 

d. where we have your explicit consent to do so for the particular purposes you have consented to; 

e. where we are authorised or required by law, or exempted by any applicable legislation, to do so; 

f. in order to enforce or defend our legal rights.

Transfers of personal data
Where your personal data has been transferred to companies within our principals’ group and/or to authorised parties located outside of the Philippines (including outside of the European Union) we take corporate, contractual and legal measures to ensure that your personal data is processed strictly on a need to know basis for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include European Commission approved transfer mechanisms for transfers to third parties in countries which have not been deemed to provide an adequate level of data protection.

You have the right in certain circumstances to: 

a. request for information on the data we hold about you; 

b. correct or update your personal information which you have provided to us; 

c. delete your personal data or withdraw consent you previously provided to us to collect / use the personal data we hold about you (where it is no longer required for a legitimate business purpose), but note that failure to provide us with the information required for us to evaluate your job application will affect our ability to evaluate your suitability for employment with us. This may negatively affect your chances of being selected for any potential employment, engagement or internship with us. 

Please contact our Data Protection Officer at if you wish to access, correct or delete your personal data, or have any questions, comments or concerns about how we handle your personal data. To assist us in dealing with your request, please provide your full name and details. Please allow us reasonable time to respond to your request and effect any change.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see for further assistance.

How long do we retain your personal data?

  • application form including personal data is deleted without delay if job application is unsuccessful;
  • retained for a time where there is a legal or regulatory reason to do so or it will become a part of your employment record if finally employed.

Where you have been unsuccessful for the job application, we will delete your personal data without undue delay unless you consent to us retaining your information for future job opportunities within our principals’ group for such longer period as informed to and agreed by you. 
Please note that in all cases, we may retain the personal data for: 

a. a longer period where there is a legal or regulatory reason to do so; or 

b. a shorter period where the individual objects to the processing of their personal data and we no longer have a legitimate purpose to retain the personal data. 

If you are successful in your application, the information collected during your application and recruitment process will become part of your employment record and will be used and retained in accordance with our Employee Privacy Notice, a copy of which will be provided to you upon commencement of employment, engagement or internship.

Changes to this Recruitment Privacy Notice
This Recruitment Privacy Notice may be changed over time. You are advised to regularly review the Recruitment Privacy Notice for any changes made. This Recruitment Privacy Notice was last updated in January 2022.