Privacy Policy นโยบายความเป็นส่วนตัว

Privacy Policy Statement for Employee


ACS Servicing (Thailand) Company Limited

1. Introduction

1.1 ACS Servicing (Thailand) Company Limited (“ACSS” or “Company”) has established and discloses this privacy policy statement (the “Privacy Policy Statement”) as the company approach to explain how ACSS, as the data controller, collect, use, disclose or otherwise process personal information of our employees (including our outsourced staffs) and ex-employees, including family members, contact persons, reference persons, guarantors, associates and other related persons of our employees and ex-employees, and how ACSS protects personal information and properly handles such information once the provisions under the Personal Data Protection Act B.E. 2562 (2019)(the “PDPA”) with respect to the processing of personal information become effective.

1.2 ACSS recognizes the importance of protecting personal information, and complies with the PDPA and other relevant laws and regulations as well as internal regulations of ACSS including this Privacy Policy Statement, and ACSS strives to properly protect and handle personal information.

1.3 ACSS collects personal information through appropriate and lawful means, and only to the extent necessary to achieve the purpose of utilization. Such collection, use, disclosure or otherwise processing of personal information will be in accordance with the provisions of relevant laws only.

1.4 ACSS specifies the purpose of collection, use, disclosure or otherwise processing of personal information, and collects such information to the extent necessary in relation to the purpose. In cases where the purpose of collection, use, disclosure or otherwise processing of specific personal information is limited by relevant laws and regulations, ACSS does not use such personal information beyond such limitations of the purpose. You may find details of purpose of collection, use, disclosure or otherwise processing of personal information in this Privacy Policy Statement.

1.5 ACSS does not disclose personal information to any third parties, except where the person concerned has granted prior consent in that regard, or where disclosure of personal information is based on laws.

1.6 ACSS takes appropriate security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction or disclosure, of personal information. When appointing any third parties to process personal information on behalf of ACSS, ACSS appropriately oversees such third parties.

1.7 ACSS reviews the content of this Privacy Policy Statement as necessary and strives to bring about continuous improvement, such as to the company’s systems and approaches for protecting personal information.

1.8 ACSS trains and educates our officers and employees regarding the importance of protecting personal information to ensure that they handle personal information of data subject under this Privacy Policy Statement in an appropriate manner.

1.9 ACSS responds in an appropriate and swift manner to requests for exercising data subject rights, any opinions or requests concerning its collection, use, disclosure, or otherwise processing of personal information. Please see relevant details shown in this Privacy Policy Statement or please contact ACSS at contact details shown below.

2. Personal Information We Collect, Use, Disclose or Process and Its Sources

2.1 What is personal information?

Personal information means any information relating to an individual, which enables the identification of such individual, whether directly or indirectly.

2.2 Personal information we collect, use, disclose or process

ACSS collects several types of personal information, including:

  • Identity data (for example, name, surname, identification card number, passport number, birth date, gender, nationality).
  • Contact data (for example, address, telephone number, email)
  • Financial data (for example, bank account, credit bureau, anti-money laundering information)
  • Information relevant to your work such as working details, work permit details, work performance evaluation, leave information, information about your use of our information and communication systems Work performance related information (for example, working details, work performance evaluation, test score, and in some cases, AEONTS may process sensitive data such as biometric data health data, religion as shown in your identification card, and criminal record only with your explicit consent or when permitted by law)
  • Personal information of your family members to the extent that is necessary for your employment benefits
  • Information obtained through video and voice recordings during your work performance such as images caught on CCTV, voice recordings during conversation with customers or other third parties

2.3 Sources of information

ACSS may collect your personal information from various sources as follows:

(1) Collect information directly from you, for example:

  • Our internal process for your employment contract, when you sign employment contract, and employee insurance and benefit claims processes.
  • Your communication with us via our contact channels, e.g. telephone, e-mail, etc.
  • ACSS online system, e.g. when you use our website or internal system, etc.

(2) Collect information from other sources, for example:

  • Government authorities such as Royal Thai Police, Anti-money Laundering Office, and court.
  • Hospital that performs health check-up for new employees.
  • From your employer (for outsourced staffs).

3. Purposes of Collection, Use, Disclosure or Processing of Personal Information

ACSS collects, uses, discloses or processes your personal information for various purposes depending on relationship between you and AEONTS as follows:

Processing purposes

Lawful basis

To perform any relevant procedures for our employment contract with you including all agreements related to employment such as Non-disclosure agreement, etc.

  • Performance of a contract

To perform our duties under employment contract and other processes related to the employment contract such as salary payment, employee data records, [hiring disability employees], generating reports for all types of leaves, work performance evaluation, probation evaluation and confirmation, provident fund applications and fund-related information management, parking permit, etc.

  • Performance of a contract
  • Compliance with a law
  • Consent for sensitive data

To comply with our legal or regulatory obligations and law enforcement request, and to report information to government authorities as required by laws, e.g. Revenue Department, Social Security Office, Department of Labour Protection and Welfare, or upon receiving an order or a writ of attachment from police officers, government authorities or courts, etc.

  • Compliance with a law

For you to perform obligations under employment contract as the employee of AEONTS including using your vein scan to ensure the information and system security of AEONTS for your performance under employment contract

  • Performance of a contract
  • Consent for sensitive data

To administer matters relating to your health and insurance such as providing health check-up, health insurance, other insurance and insurance claim, etc.

  • Performance of a contract
  • Consent for sensitive data

To provide trainings for employees as agreed or determined in the employment contract and company policy, regulations, or work rules

·         Performance of a contract

To monitor security in and around our head office, regional offices, branches or premises through CCTV system

  • Legitimate interest

To support your loan and/or credit card application by providing your employment status to a commercial bank

  • Consent

To manage and resolve any complaints regarding performance under employment contract including detection, investigation, or other legal process

  • Legitimate interest
  • Legal obligation

To establish, comply or exercise the rights to legal claims or defend against the rights to legal claims

  • Legitimate interest
  • Legal claim for sensitive data

To maintain your records after your employment with us ended as our future reference for your re-application

  • Consent

To disclose to our customers, vendors or other third parties due to the rights and obligations for work performance under employment contract

  • Performance of a contract
  • Legitimate interest

To disclose to our agencies, service providers or sub-contractors for any operations of ACSS

  • Performance of a contract
  • Legitimate interest
  • Consent for sensitive data

4. Data Retention Period

ACSS retains your personal information for as long as is considered necessary for the purpose for which it was collected, used, disclosed or processed as set out in this Privacy Policy Statement. The criteria used to determine our retention periods include: (I) we retain the personal information for the duration we have an ongoing employment relationship with you; or we may retain the personal information for a longer period as necessary to comply with applicable laws, or to be in accordance with legal prescription, or to establish, comply with or exercise the rights to legal claims or defend against the rights to legal claims, or to be complied with, for any other cause, our internal policies and regulations.

5. Data Disclosure

ACSS may disclose your personal information in certain circumstances, for the purposes set out in this Privacy Policy Statement, to:

5.1 Government authorities, supervising authorities or other authorities as stipulated by laws, including competent official, e.g. courts, police officers, Social Security office, Revenue Department, Immigration Bureau, Ministry of Commerce, Student Loan Fund.

5.2 ACSS parent company in Japan for internal administrative purposes such as handling employees’ complaint.

5.3 Our customers, vendors or other third parties due to the rights and obligations for work performance under employment contract.

5.4 Agencies, contractors/sub-contractors and/or service providers for their implementation and procedure such as document storage and destruction service providers, printing house, IT development companies, auditor, lawyer, consultants, etc.

5.5 External training institutes.

5.6 Banks or credit card companies expected to have a legal relationship with you.

5.7 Hospital for your annual health check-up.

5.8 Insurance companies.

5.9 Provident fund management company.

6. Data Subject Rights

6.1 Your rights under the PDPA

According to the PDPA, you have certain rights relating to your personal information as follows:

(1) Right to Withdraw Consent

You have the right to withdraw consent given to us for collecting, using or disclosing your personal information at any time, unless there is a restriction of the withdrawal of consent by law or the contract which gives benefits to you.

However, the withdrawal of consent shall not affect the collection, use or disclosure of personal information you have already given consent legally. In addition, where you withdraw consent, you may experience less convenience in working with ACSS, or may not receive employees’ benefits or special offers.

(2) Right to Access

You have the right to request access to and obtain a copy of your personal information, which is under our responsibility, or to request the disclosure of the acquisition of the personal information obtained without your consent. At our discretion, we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal information, we may charge a reasonable processing fee.

(3) Right to Data Portability

Where ACSS arranges your personal information to be in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means, you have the right to receive your personal information and are also entitled to:

   (a) request ACSS to send or transfer your personal information in such formats to other data controllers if it can be done by the automatic means;

   (b) request to directly obtain your personal information in such formats that we send or transfer to other data controllers, unless it is impossible to do so because of the technical circumstances.

(4) Right to Object

You have the right to object to the collection, use, disclosure or otherwise processing of your personal information on grounds stipulated by law. ACSS will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process your personal information for the establishment, exercise or defence of a legal claim.

(5) Right to Erasure

You have the right to request ACSS to erase, destroy or make your personal information become unidentifiable data, under certain circumstances unless ACSS is required to retain your personal information in order to comply with a legal obligation or to establish, exercise or defend legal claims.

(6) Right to Restriction of Processing

You have the right to request ACSS to restrict the use of your personal information under certain circumstances where you believe such personal information to be inaccurate, our processing is unlawful; or ACSS no longer needs to process such personal information for a particular purpose, but where ACSS is not able to delete the data due to a legal or other obligation or because you do not want ACSS to delete it.

(7) Right to Rectification

ACSS will ensure that your personal information remains accurate, up-to-date, complete, and not misleading. However, if you consider that your personal information is inaccurate or changed, you have the right to request ACSS to rectify your personal information to be accurate, up-to-date, complete, and not misleading.

6.2 How to exercise your rights

You may exercise the data subject rights listed above via the following channels:

  • SAP SuccessFactors System of the Company (for consent withdrawal)
  • Channels specified in Clause 8 below.

Nonetheless, if we reject your request, we will inform you of the reasons.

In addition, outsource staffs may withdraw their consent by notifying head of section in charge of your outsourcing contract.

6.3 Processing time

ACSS will process your request within 30 days upon receipt of your valid request together with complete supporting documents. Until then, your personal information will still be unchanged in our database and may still be processed or you may be contacted by us, our partners or those who have retained your personal information as of the date of your request.

7. Data Protection Security Measures

7.1 Implementation of Security Measures

ACSS implements appropriate security measures for preventing unauthorized or unlawful loss, access to, use, alteration, correction or disclosure of personal information.

7.2 Disclosure of Personal Information to Data Processor

ACSS properly supervises third parties which ACSS has appointed to process personal information pursuant to our orders or on our behalf.

8. Contact information

If you have any questions or inquiries about the protection of your personal information, collection, use or disclosure of your personal information, or exercise of your rights, or have any claims, please contact us at:

ACS Servicing (Thailand) Company Limited and Data Protection Officer (Mr. Alongkorn Sattabusaya)

Address:    699 Modernform Tower, 11th Floor, Srinagarindra Road, Phathanakan, Khet Suan Luang, Bangkok 10250

E-mail:       [email protected]

Tel:           02-769-1700 ext. 77940-43

You also have the right to file a complaint with the relevant Personal Data Protection Committee if ACSS violates or does not comply with the PDPA or other regulations or notifications issued in accordance with the PDPA.

9. Third Party Links

This Privacy Policy Statement applies to the use of website only. When you link to third parties’ websites via ACSS Website, the personal information protection shall be in accordance with the privacy policy statement of such third parties’ websites which are not related to ACSS.

10. Update to this Privacy Policy Statement

ACSS regularly reviews and, if appropriate, updates this Privacy Policy Statement from time to time to ensure that your personal information is properly protected. In case of any update to this Privacy Policy Statement, ACSS will inform you through Privacy Policy Statement on this website or other appropriate methods. Please refer to this page for the updated Privacy Policy Statement.