Q14: Would an employer be exempted from disclosing its identity by providing a PICS if it wants to directly solicit personal data from job applicants in a recruitment advertisement?
A: No. An employer needs to provide a PICS only when job applicants are required to provide personal data. If an employer merely asks job applicants to contact the company by telephone or request an application form by mail, a PICS would not be required at this stage. However, if an employer wants to solicit personal data directly from job applicants in a recruitment advertisement, it must identify itself in the first place.
Example of Q14

Q15: Can an employer invite job applicants in a recruitment advertisement to submit a job application online at the employer's website?

A: An employer may do so but must ensure compliance with the requirements of the Code as an application invited online amounts to the collection of personal data from applicants. When an employer requires job applicants to submit personal data in an online format on the company web page, the identity of the employer should be disclosed, and the PICS notification requirement complied with. In this case, the PICS can be displayed as a linked page to the online form or as a 'pop-up" screen when a 'confirm' button is pressed prior to the transmission of the online form (section 2.2.6 of the Code).