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Privacy policy for the Middleton International School Thailand employer branding and recruitment

Date of publication: 01-01-2026

We at Middleton International School Thailand manage our employer branding and recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.

In this privacy policy, we explain how we process your personal data if:

  1. You visit our Career Site (you being a “Visitor”)
  2. You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)
  3. You apply for a position with us, via our Career Site or a third party service (you being an ”Applying Candidate”)
  4. We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)
  5. We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)
  6. We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).

This Privacy Notice describes how we collect, use, disclose, and otherwise process personal data in connection with our recruitment activities in Thailand. It also explains your rights under applicable data protection laws and how you can exercise those rights.

When we use the term “Candidate” in this Privacy Notice, we are referring to Connecting Candidates, Applying Candidates, Sourced Candidates, and Referred Candidates, unless stated otherwise.

1. About Processing of Personal Data

“Personal data” means any information relating to an identifiable individual, whether directly or indirectly. Examples include name, email address, telephone number, identification information, and online identifiers such as IP addresses.

“Processing” of personal data means any operation performed on personal data, whether automated or not, such as collection, use, disclosure, storage, analysis, transfer, or deletion.

Our processing of personal data is governed by the Thailand Personal Data Protection Act B.E. 2562 (2019) (“Thailand PDPA”) and other applicable laws.

Under the Thailand PDPA, a data controller is the person or entity that determines the purposes and means of processing personal data. A data processor processes personal data on behalf of the data controller, following its instructions.

We act as the data controller when processing your personal data as described in this Privacy Notice.

2. What Personal Data Do We Process?

All Individuals

- Device information – such as IP address, browser type and version, device identifiers, operating system, screen resolution, preferred language, geographic location, and device usage data.

- Technical and statistical data – such as visited URLs, session behaviour, traffic source, and interactions with the Career Site.

- Communications data – including emails, messages, video recordings, survey responses, social media messages, and information you submit through your account.

- Contact details – such as name, email address, telephone number, and physical address.

Candidates

- Recruitment process data – interview notes, assessment results, test outcomes, and salary expectations.

- Application information – CVs, cover letters, work samples, education history, references, and recommendation letters.

- Public profile information – information from publicly available sources related to your professional background (e.g. LinkedIn or employer websites).

- Reference information – information provided by referees or persons who recommend you.

3. Sources of Personal Data

All Individuals

- From the Career Site – technical, statistical, and device information.

- Directly from you – when you apply, communicate with us, or interact with our recruitment process.

You may choose not to provide certain personal data. However, some information is necessary to process your application or respond to your requests.

References

- From Candidates – if you are listed as a reference, we receive your contact details from the Candidate.

Candidates

- Public sources – such as professional networking sites or employer websites.

- Referrals – from our employees, partners, or recruitment service providers.

- Your references – information provided by referees you nominate.

- Data generated during recruitment – including interview notes and assessment results created by us or jointly with you.

4. Purposes of Processing Personal Data

We process personal data for the following purposes:

- Protecting and enforcing our legal rights and interests, including handling legal claims or disputes.
Affected individuals: All relevant categories
Personal data used: All categories listed above

- Sharing personal data with recipients as described in Section 5.
Affected individuals: Depends on purpose
Personal data used: All relevant categories

- Operating and securing the Career Site, including system maintenance, testing, and security monitoring.
Affected individuals: Visitors
Personal data used: Device information; Technical and statistical data

- Analysing usage and performance of the Career Site to improve functionality and user experience.
Affected individuals: Visitors
Personal data used: Device information; Technical and statistical data

- Providing job vacancy updates.
Affected individuals: Connecting Candidates
Personal data used: Contact details; Communications data

- Reviewing applications and candidate profiles, including communications during recruitment.
Affected individuals: Connecting Candidates; Applying Candidates
Personal data used: All relevant categories

- Proactively sourcing and evaluating candidates.
Affected individuals: Sourced Candidates; Referred Candidates
Personal data used: All relevant categories

- Contacting candidates regarding future vacancies.
Affected individuals: Candidates
Personal data used: All relevant categories

- Recording interviews, where applicable.
Affected individuals: Candidates
Personal data used: Communications data

- Conducting surveys related to recruitment or employer branding.
Affected individuals: Candidates
Personal data used: All relevant categories

- Contacting and evaluating references.
Affected individuals: References
Personal data used: Contact details; Communications data

5. Disclosure of Personal Data

We may share your personal data with:

- Service providers – including recruitment platforms, ATS providers, assessment providers, and IT service providers.

- Group companies – where they support recruitment operations or systems.

- Cookie providers – where you have consented, as described in our Cookie Policy.

- Government authorities or regulators – where required by law.

- Parties involved in legal proceedings – where necessary to protect or defend legal rights.

- Business transaction parties – in connection with mergers, acquisitions, financing, or asset transfers.

6. Legal Bases for Processing

Under the Thailand PDPA, we process personal data based on one or more of the following legal bases:

- Performance of a contract or steps prior to entering into a contract (e.g. recruitment).

- Legal obligation under applicable laws.

- Legitimate interests of the company, provided such interests do not override your fundamental rights and freedoms.

- Consent, where required (e.g. recording interviews).

Where processing is based on consent, you may withdraw your consent at any time (see Section 9).

7. Transfer of Personal Data Outside Thailand

We may transfer personal data outside Thailand where our service providers, group companies, or other recipients are located overseas.

When transferring personal data internationally, we ensure appropriate safeguards are in place in accordance with the Thailand PDPA, such as:

- Adequate data protection standards in the recipient country; or

- Contractual safeguards ensuring equivalent protection; and

- Appropriate technical and organisational security measures.

You may contact us for further details on international transfers.

8. Data Retention

All Individuals

We retain personal data as long as necessary to fulfil legal, regulatory, or dispute-related purposes.

Visitors

Personal data is retained for up to one (1) year for security and performance analysis, subject to cookie retention periods.

Candidates

- Connecting Candidates: retained while you remain connected with us.

- Other Candidates: retained for recruitment decision-making and consideration for future roles.

- If hired: personal data will be retained in accordance with employment-related privacy notices.

References

Personal data is retained as long as the related Candidate’s data is retained.

9. Your Rights Under the Thailand PDPA

You have the following rights under the Thailand PDPA:

- Right to be informed

- Right of access

- Right to data portability

- Right to object to processing

- Right to request deletion or destruction

- Right to request restriction of processing

- Right to rectification

- Right to withdraw consent

- Right to lodge a complaint

You may exercise your rights by:

- Visiting the Data & Privacy page on our Career Site;

- Logging into your account settings; or

- Contacting us at hrd@etonhouse.com.sg

You may lodge a complaint with the Personal Data Protection Committee (PDPC) of Thailand.
More information is available at:
👉 https://www.pdpc.or.th/en/home/


10. Contact Information

For questions, concerns, or requests relating to this Privacy Notice or your personal data, please contact:

Email: hrd@etonhouse.com.sg


11. Updates to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our processing practices or legal requirements. We encourage you to review this page regularly. The last updated date will be displayed at the top of the notice.


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