Clause
Purposes
Lawful Basis
Personal Data Privacy Notice
For Directors, Top Executives and the Persons Who May Become Directors or Top Executives of GC
Global Connections Public Company Limited (hereinafter referred to as “GC”) gives highest priority to the protection of the personal data of directors, top executives and the persons who may become directors or top executives of GC, and in order for you to ensure that we will protect and manage your personal data in accordance with the laws concerning personal data protection, we then established this Personal Data Privacy Notice for your acknowledgement of details of the processing of personal data, whether it be the collection, use and disclosure (collectively referred to as the “Processing”) that may be occurred, including to inform you of the rights on your personal data and our contact channels as follows:
1. Purposes for the collection, use and disclosure of personal data
In case that you are a director, top executive and the person who may become director or top executive of GC, it is necessary for us to collect, use and disclose your personal for the following purposes:
1.1
For the proceedings necessary for the consideration and selection of directors of the Company or top executives which shall mean to include the process for evaluation, selection and appointment as well as other internal work management procedures in relation to the consideration and selection as director or top executive.
Contractual, legitimate interests and legal obligation basis
1.2
For the relevant proceedings between you and GC including the relevant proceedings in case that you are a representative or the person who acts on behalf of GC, such as:
- The payment of remuneration to directors of the Company or top executives including any necessary proceeding in relation to the payment of remuneration;
- The preparation and collection of personal data including the profile of the directors of the Company or top executives as GC’s database;
- For providing documents and agenda of the meeting;
- For proposing for appointment as a director of related external organizations and/or to be positioned in other relevant organizations such as the Federation of Thai Industries, etc.;
- For the disclosure of information through GC’s website and/or sending to external organizations in support of the application for enrolling in relevant learning sessions, receiving awards or any other activity participated by you as a director of the Company or top executive of GC;
- The disclosure of information such as profile, name-surname, securities holding information, age, education, work profile and directorship, etc. through relevant media such as publications, advertisements, electronic media and websites, etc. for acknowledgement by the third parties;
- The collection, use and/or disclosure of personal data of directors of the Company and top executives of GC for carrying out business and management of GC’s business including for using as supporting evidence for conducting transactions of GC;
- The disclosure of information and verification of personal data (Know Your Customer – KYC) in relation to the conducting of transactions with onshore and offshore banks;
- The disclosure and reporting of information of directors and top executives to the relevant regulatory authorities for acknowledgement;
- The inspection of information on the interest of directors, top executives and the related persons of the directors and top executives and conflict of interest transactions of GC for collecting as an information and reporting relevant information such as the securities holding, the reporting of strategic shareholder, to the regulatory authorities for acknowledgement;
The disclosure of information necessary for the compliance with relevant evaluation criteria participated by GC.
Contractual, legitimate interests and legal obligation basis
1.3
For using as information on the application for using electronic system or enabling the right to access or use internet or relevant electronic systems.
Legitimate interests
1.4
For the compliance with laws concerning public company limited, laws concerning securities and exchange including the process for appointment, registration of change or any proceeding under relevant laws.
Legal obligation basis
1.5
For the compliance with laws or compliance with court’s summon, letter or order of authorities, independent organizations or officers having duties and powers under the laws such as the compliance with a summon, writ of attachment, order of the court, police officers, public prosecutors and government authorities including the reporting or disclosure of information to the shareholders, government authorities or independent organizations such as Energy Regulatory Commission, Ministry of Energy, Revenue Department, Land Department, State Audit Office of Thailand, the Office of National Anti-Corruption Commission, etc. for compliance with relevant laws.
Legal obligation basis
1.6
For the establishment of legal claim, the granting or obtaining of authority, the compliance, exercise or defense of legal claim and relevant proceedings as well as the proceedings for legal execution.
Legitimate interests and legal obligation basis
1.7
For the collection and use of your personal data such as name-surname, position, work unit, picture-video in case that you participated in the meetings, activities or relevant proceedings relating to GC for dissemination or public relations through relevant channels such as internal email of GC, GC’s website, Facebook, LINE, YouTube or other online media of GC or other media such as television and publication, etc.
Legitimate interests basis
1.8
For the business planning, reporting and estimation, opinion survey, improvement of GC’s operation, risk management, audit supervision including the internal audit of the internal audit office and internal management in the organization, including for the utilization for internal operations within GC in relation to the disbursement of payment of the accounting and finance unit of GC.
Legitimate interests basis
1.9
For maintaining security in building area or premises of GC and the evaluation of security risks including the communication for the issuance of access card(s) to work in the premises of GC, the exchange of cards for building entry and exit, the requesting for car sticker, the recording of information on the entry and exit of GC’s premises, and the recording of videos in the buildings or offices of GC or GC’s branches by closed-circuit television (CCTV).
Legitimate interests basis
1.10
For the management and administration concerning your heath, hygiene and safety.
Preventing or suppressing danger to a person’s life, body or health (Vital Interests)
1.11
For the compliance with laws concerning public interest in respect of public health such as health protection against dangerous communicable disease or epidemic which may be contagious or spread into the kingdom.
Legitimate interests basis
1.12
For contacting and communication in case of necessity or emergency.
Legal obligation basis
1.13
For the inspection of information on the interest of directors, top executives and the related persons of the directors and top executives, and conflict of interest transactions of GC for collecting as an information and reporting relevant information such as the securities holding, the reporting of strategic shareholder to the regulatory authorities for acknowledgement.
Legitimate interests and legal obligation basis
In some circumstances, we may collect, use and disclose personal data of the person in the family or other person that the directors, top executives and the persons who may become directors or top executives of GC have provided for the Company. In this respect, GC shall collect, use and disclose personal data of those people under relevant lawful basis for the following purposes:
GC would like to inform you that for the Processing of personal data of the directors, top executives and the persons who may become directors or top executives of GC, we rely on relevant lawful basis as specified herein without relying on the consent; however, there might be the processing of personal data in certain cases that we could not rely on these lawful basis such as the cases required by laws to obtain consent from the owner of personal data for the Processing of sensitive personal data, etc. For such cases, GC shall request for your express consent (please read our letter requesting for consent in addition to this document) and in case that you, as the director, top executive and the person who may become director or top executive of GC, have provided other personal data of the person in the family or the other person for us, you shall be responsible to inform those people of this Personal Data Privacy Notice and/or proceed to obtain consent (if necessary).
The aforementioned personal data collected by GC is the information necessary for GC’s performance of agreements or compliance with your request prior to entering into agreement, if you refuse to provide such necessary personal data, GC may not be able to carry out relevant proceedings in relation to the consideration or selection for you.
2. Personal Data which shall be collected
In general, for the collection of your personal data, GC shall collect your personal data by directly requesting the data from you; nonetheless, there may be some circumstances that GC collects your personal data from other sources such as the organization that you are positioned in, your secretary or coordinator, government authorities or state authorities or other sources of publicly disclosed information such as website and searchable data on the internet, etc.
In this regard, GC shall proceed to collect your personal data as follows:
2.1 General personal data
(1) Identity data such as first name, last name, identification card number, passport number, date of birth, gender, age, nationality, marriage status, signature and photo;
(2) Contact data such as address, phone number and email;
(3) Financial data such as bank account number and salary;
(4) Other personal data such as work profile and educational profile as well as relevant evidence, military conscription status, information of the person of reference and the family member;
(5) Opinions or recommendations.
(6) Data of the recording of video and voice during the operation such as the recording of video by closed-circuit television;
(7) Data on the participation of relevant activities of the Company such as the recording of photo or video;
(8) Data of the securities of the Company held by the directors, top executives and the related persons of the directors and top executives.
(9) Data concerning the utilization of relevant information systems of GC including information regarding the utilization of application, website browsing information such as website browsing history, IP address information, etc.
2.2 Sensitive personal data
GC has no intention to collect and use religious and blood type data specified in your identification card for any specific purpose. In the event that you provided GC the copy of your identification card, it is requested that you conceal such data. If you did not conceal such data, it shall be deemed that you authorized GC to conceal those data and it shall be deemed that such document with concealed data be valid and legally enforceable in all respects. In case that GC is unable to conceal those data due to some technical limitation, GC shall collect and use such data as a part of your identification documents only.
However, if it is necessary for GC to collect sensitive personal data for any specific purpose that GC could not rely on lawful basis for the Processing, GC shall request for your prior express consent. In this regard, GC may process the following sensitive personal data:
(1) Religious data;
(2) Criminal record data;
(3) Health data such as food allergy data, drug allergy data and blood type.
3. Period for retention of personal data
GC shall retain your personal data for the period necessary for the purposes of the collection, use or disclosure of personal data set out in this Privacy Notice and the personal data shall be further retained for the period necessary for the compliance with laws or the statutory prescription period, or for the establishment, compliance, exercise or defense of legal claim, or for other reasons pursuant to the internal policies and rules in the organization of GC.
4. Disclosure of personal data
In order to carry out the proceedings for the purposes set out in this Privacy Notice, GC may disclose your personal data to the third parties as follows:
4.1 The government authorities, regulatory authorities or other authorities as prescribed by laws including the officers which exercise powers under the laws such as the Department of Business Development, the Office of Securities and Exchange Commission (SEC), Securities Exchange of Thailand (SET), State Enterprise Policy Office (SEPO), the Office of National Anti-Corruption Commission (NACC Office), the National Anti-Corruption Commission, the Institute of Directors of Thailand (IOD), courts and police officers;
4.2 Agents, contractors/sub-contractors and/or service providers for any operation provided for GC such as auditors, lawyers and legal advisors;
4.3 Banks that GC conducted financial transactions, investment, both onshore and offshore banks;
4.4 Other third parties such as the disclosure of information through website, the public relations of activity photos or news and information on the conducting of activities or projects of GC to the mass media or third parties, etc.
5. Your rights as the owner of personal data
As the owner of personal data, you have the rights as prescribed in the Personal Data Protection Act B.E 2562 (2019). In this respect, you can request to exercise your relevant rights through the channels specified by GC in Clause 7 or through GC website, whereby you will be entitled to exercise the rights when the laws concerning personal data protection are applied to GC. In this respect, your relevant rights shall have details as follows:
5.1 Right to withdraw consent
In case that GC requests for your consent, you shall have the right to withdraw the consent for the Processing of your personal data that has already given to GC unless such withdrawal of consent is restricted by laws or by the agreement that provides you the benefits.
Such withdrawal of consent shall not affect the Processing of personal data legally conducted according to your prior consent.
5.2 Right to access to personal data (Right to Access)
You have the right to request for an access to and the request for the copy of your personal data under control of GC, including to request GC to disclose the acquisition of such data that you have not given consent to GC.
5.3 Right to request for the submission or the transfer of personal data (Data Portability Right)
You have the right to request GC to transfer your personal data that you have given to GC as prescribed by laws.
5.4 Right to object the collection, use or disclosure of personal data (Right to Object)
You have the right to object the Processing of data relating to you in respect of the collection, use or disclosure of your personal data as prescribed by laws.
5.5 Right to request for the erasure of personal data (Erasure Right)
You have the right to request GC to delete your personal data as prescribed by laws. Nevertheless, GC may store your personal data using electronic system pursuant to which the systems may be unable to delete the data, and for such case, GC shall destroy or cause such data to be unable to identify your identity.
5.6 Right to request the restriction of the use of personal data (Right to Restrict Processing)
You have the right to request GC to restrict the use of your personal data as prescribed by laws.
5.7 Right to request for the rectification of personal data (Rectification Right)
If you found that the data controlled by GC is incorrect or you have changed your personal data, you have the right to request GC to correct your personal data so that such personal data be accurate, current, complete and not causing misunderstanding.
5.8 Right to lodge a complaint
You have the right to lodge a complaint with the competent officers under the Personal Data Protection Act B.E 2562 (2019) in case that GC breaches or does not comply with such Act.
6. Amendment of this Privacy Notice
We may amend and update this Privacy Notice from time to time, and if there is such amendment, we will keep you posted through GC website and/or inform you via email. If it is necessary to request for your consent, we will proceed to request additional consent from you.
7. Contact channels
If you have question or require further details concerning the protection of your personal data, the collection, use and disclosure of your personal data, the exercising of your rights or if you have any complaint, you can contact GC as per the following channels:
Global Connections Public Company Limited
Office Address: 13/1 Moo2 Kingkaew Rd, Rachateva, Bangplee, Samuthprakarn 10540
Telephone : 0 2763 7999
E-mail : compliance@gc.co.th
Announced 1 July 2022