Data Processing in the Employment Context
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Data Processing in the Employment Context Start Comparison
Is an identified legal basis required in order to collect or process personal data or sensitive personal data in the employment context?

Last review date: 15 January 2025

Yes.

The potential legal bases for data processing in the employment context are:

The requirements for personal data collected or processed in the employment context are the same as for personal data collected and processed in other contexts.

Can consent be validly obtained in the employment context?

Last review date: 15 January 2025

Yes, same as for data subjects outside the employment context.

Exceptions to the consent requirement, which are purpose-based, are provided in the PDPA. Each of the following are exceptions to the requirement to obtain consent in the context of employee personal data: (a) the personal data is collected by the employer when entering into an employment relationship with the individual or appointing the individual to any office; (b) the personal data is collected by the individual's employer and the collection is reasonable for the purpose of managing or terminating the employment relationship, which includes using the employee's bank account details to issue salaries, monitoring how the employees use company computer network resources, and managing staff benefit schemes; (c) the collection, use or disclosure of personal data is necessary for evaluative purposes, which include determining the suitability, eligibility or qualifications of an individual for continuance and/or promotion in employment; and (d) personal data is included in a document produced in the course and for the purposes of the individual's employment, business or profession, for purposes consistent with those for which the document was produced.

Has the data privacy regulator issued guidance on use of artificial intelligence, automated decision making or profiling in an employment context – for example, relating to use in employee monitoring or hiring?

Last review date: 15 January 2025

Yes

If yes, please provide a link.

The PDPC published a consultation paper on 18 July 2023 on the proposed guidelines on how the PDPA applies to the collection and use of personal data to develop and deploy artificial intelligence systems that embed machine learning models used to make decisions, recommendations or predictions. On 1 March 2024, the PDPC issued its closing note on the public consultation and subsequently published their Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems.

See: https://www.pdpc.gov.sg/-/media/files/pdpc/pdf-files/advisory-guidelines/advisory-guidelines-on-the-use-of-personal-data-in-ai-recommendation-and-decision-systems.pdf

On 15 July 2024, the PDPC also issued their Proposed Guide on Synthetic Data Generation, which aims to help organizations understand synthetic data generation techniques and potential use cases, particularly for artificial intelligence.

See also: https://www.pdpc.gov.sg/-/media/files/pdpc/pdf-files/other-guides/proposed-guide-on-synthetic-data-generation.pdf