Business Contact Privacy Notice

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Document Ref: EDMS-PRV-NTC-001 • Rev 00 • Effective: 3 September 2026

EDMS Consultants Sdn Bhd (199901008869 (483769-K)) ("EDMS", "we", "us", or "our") is committed to protecting personal data under our control. This notice explains how we collect, use, disclose, retain, and protect personal data relating to individuals who represent or work for our clients, prospective clients, vendors, service providers, business partners, and professional advisers.

1. Purpose

EDMS Consultants Sdn Bhd is committed to protecting personal data under our control. This Business Contact Privacy Notice explains how we collect, use, disclose, retain, and protect personal data relating to individuals who represent or work for our clients, prospective clients, vendors, service providers, business partners, and professional advisers.

This notice is issued in accordance with the Personal Data Protection Act 2010 ("PDPA") and applicable EDMS policies. EDMS processes personal data in accordance with the Personal Data Protection Act 2010 (Act 709), Personal Data Protection (Amendment) Act 2024 including applicable amendments, regulations, standards, and guidance issued by the Personal Data Protection Commissioner.

2. Scope

This notice applies to business-contact information processed in connection with a commercial or professional relationship, including enquiries, quotations, proposals, tenders, projects, contracts, supplier arrangements, meetings, events, invoices, payments, compliance matters, and business communications.

This notice does not replace EDMS's Employee Privacy Notice, which applies separately to employee, job-applicant, dependent, and emergency-contact data. This Privacy Notice is issued pursuant to and shall be read together with EDMS-QMS-POL-002, Personal Data Protection and Privacy Policy.

3. Categories of Personal Data

EDMS may collect and process the following business-contact information:

  • Your name, job title, department, employer or organisation name, and business address.
  • Your business email address, business telephone number, and other professional contact details.
  • Information contained in correspondence, meeting records, quotations, proposals, contracts, purchase orders, invoices, payment records, project files, and service-delivery records.
  • Information about your role, authority, approvals, signature, and authorisation where needed for contracts, payments, or business decisions.
  • Limited identification or verification information where required for legal, regulatory, contractual, compliance, or due-diligence purposes.

EDMS does not ordinarily collect sensitive personal data from business contacts. If sensitive personal data is needed for a specific purpose, we will handle it in accordance with the PDPA and applicable legal requirements.

4. Purpose of Processing

EDMS uses business-contact information only for legitimate business and commercial purposes, including to:

  • Respond to enquiries and manage business communications.
  • Prepare and manage quotations, proposals, tenders, contracts, projects, and service delivery.
  • Manage relationships with clients, suppliers, vendors, business partners, and professional advisers.
  • Administer meetings, events, training, project coordination, and operational communications.
  • Process invoices, payments, reconciliations, and other finance or procurement activities.
  • Conduct due diligence, compliance monitoring, risk management, internal audit, management review, dispute management, and record keeping.
  • Comply with legal, regulatory, tax, audit, contractual, and professional obligations.
  • Protect EDMS's legal rights and interests, including preventing, investigating, or managing fraud, misconduct, disputes, or legal proceedings.

Providing business contact information is generally voluntary. However, where information is necessary for EDMS to respond to an enquiry, enter into or administer a contract, provide services, process payment, meet compliance requirements, or communicate with your organization, failure to provide the relevant information may prevent EDMS from carrying out that activity.

EDMS will not use business-contact information for unrelated purposes without providing an appropriate notice or obtaining consent where required.

5. Source of Personal Data

EDMS may collect business-contact information directly from the relevant individual, from the organization they represent, through business correspondence, meetings, quotations, contracts, purchase orders, invoices, publicly available professional sources, referrals, or authorized third parties.

6. Disclosure of Personal Data

EDMS discloses business-contact information only on a need-to-know basis and where necessary for the purposes described in this Notice. Personal data may be disclosed to:

  • Authorized EDMS employees and management.
  • Clients, vendors, suppliers, service providers, subcontractors, and business partners involved in the relevant engagement or transaction.
  • Banks, payment providers, auditors, tax agents, legal advisers, insurers, and other professional advisers.
  • Approved cloud-service providers and data processors, including business systems used by EDMS, subject to applicable contractual, security, and compliance safeguards.
  • Government agencies, regulators, law-enforcement authorities, and statutory bodies where disclosure is required or authorized by law.

7. Cross-Border Transfers

Where EDMS uses cloud systems, service providers, or professional advisers located outside Malaysia, business-contact information may be transferred outside Malaysia where necessary for the stated purposes. EDMS will apply appropriate contractual, organizational, and security safeguards for such transfers.

8. Security of Personal Data

EDMS applies appropriate technical and organizational measures to protect business-contact information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. These measures include access controls, least-privilege access, authentication controls, controlled document storage, confidentiality obligations, secure system configuration, and periodic access reviews.

9. Retention of Personal Data

EDMS retains business-contact information only for as long as necessary for the purposes described in this notice and to meet legal, regulatory, tax, audit, contractual, dispute-management, and record-keeping obligations.

As a general rule, relevant business and financial records may be retained for up to seven years after the end of the relevant business relationship or transaction. We may retain information for a longer period where required by law, a litigation hold, audit requirements, or a legitimate business necessity. When personal data is no longer needed, we will securely delete, destroy, or anonymise it, as appropriate.

10. Your Rights

Subject to the PDPA and applicable exemptions, you may:

  • Request access to personal data that EDMS holds about you.
  • Request correction of personal data that is inaccurate, incomplete, misleading, or not up to date.
  • Make an enquiry or complaint about EDMS's processing of your personal data.
  • Ask EDMS to stop sending direct-marketing communications, where EDMS uses your business-contact information for that purpose.

To make a request or raise a privacy concern, contact our Compliance Manager using the details in Section 12. Please provide sufficient information for us to verify your identity and locate the relevant records. We may ask for further information where reasonably necessary and will respond in accordance with applicable law.

11. No Separate Signed Acknowledgement Required for Routine Business Contacts

For routine business-contact information processed solely to manage a business-to-business relationship or commercial transaction, EDMS does not normally require a separate signed acknowledgement of this notice.

This does not affect EDMS's obligation to provide appropriate privacy information or obtain consent where consent is required by law. Where EDMS intends to use personal data outside normal business administration, we will provide an appropriate notice and obtain consent where necessary.

12. Contact Point

For privacy-related enquiries, complaints, or requests to access or correct personal data, please contact our Compliance Manager:

info@edms-consultants.com

13. Changes to this Notice

EDMS may update this Notice from time to time to reflect changes in law, systems, service providers, business operations, or internal compliance requirements. The effective date above reflects the date this notice was last updated.

14. Approval

This Business Contact Privacy Notice (EDMS-PRV-NTC-001, Rev 00) has been reviewed and approved for publication by EDMS Consultants Sdn Bhd.