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The Personal Data Protection Act in short, PDPA provides that a data intermediary that processes personal data on behalf of and for the purposes of another organisation pursuant to a contract which is evidenced or made in writing will only be subject to the provisions in the PDPA relating to the safeguarding and retention of personal data in respect of such processing. In certain circumstances these recruitment agencies could qualify as data intermediaries,”
Under the Act, organisations are also not required to seek consent for the collection, use or disclosure of personal data if it is intended for evaluative purposes such as a background check, or when the information is publicly available, such as through newspapers, phone directories or the internet.