Privacy Policy

This Privacy Policy (“Policy”) sets out the basis which POLWEL Co-operative Society Limited (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of the persons to whom this policy applies in accordance with the Singapore Personal Data Protection Act (“PDPA”).

This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes.

PERSONAL DATA

  1. As used in this Policy, personal data means data, any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information.
  1. Data intermediary in this Policy means an organisation which processes personal data on behalf of another organisation (the data controller).
  1. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  1. The types of personal data that we may collect from you include (but may not be limited to) the following:
    (a)    Personal details (e.g. name, email address, personal identity card details, date of birth, contact number)

(b)    Voice, Photos and Video recordings (during WSQ security assessments / our workshops or trainings)

(c)    Financial details (e.g. banking details, account number, income / expenses, credit history details)

For job applicants or individuals seeking career transition and support services

(d)    a to c above;
(e)    education qualifications, employment history, personal details of references and;
(f)    health information

  1. We generally do not collect your personal data unless:
    (a)    it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after:
  • you (or your authorised representative) have been notified of the purposes for which the data is collected, and
  • you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or

(b)    collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

  1. You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in clause 16. However, if you choose not to provide us with the personal data intended for the purpose(s) for which you have been notified, we may not be able to fulfil the said purpose(s).
  1. If we are a Data Intermediary, we will ensure the limited processing of personal data to the purposes specified by the Data Controller and according to their instructions.
  1. We may collect, use or disclose your personal data without consent pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
  • To respond to an emergency that threatens your life, health and safety or of another individual;
  • Necessary in the national interest; and
  • We have a legitimate interest for the lawful collection, use or disclosure of personal data without consent. For example, where it is necessary for the society to recover debt, prevent misuse of services, conduct necessary corporate due diligence or improving our products and services . We take due care to assess and balance our legitimate interests against your personal data rights and ensure that our legitimate interests outweigh any likely residual adverse effect to you.
  1. We may collect, use and disclose your personal data for any or all of the following purposes:
    (a)    performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b)    quality management and internal training;

(c)    responding to and handling your feedback, queries, requests, applications;

(d)    verifying your identity and accuracy of information provided;

(e)    processing your loans and/or deposits related matters;

(f)    facilitate private security licensing and WSQ assessment related matters;

(g)    administering training records and registration services;

(h)    administering payments;

(i)    creation and maintenance of user accounts for our system(s);

(j)    conducting audits and ensuring compliance;

(k)    processing and maintenance of your membership;

(l)    facilitate security clearance for entry to premises;

(m)    marketing and publicity;

(n)    sending you information regarding your membership benefits, such as promotions on products and services offered, as well as available employment/career opportunities;

(o)    notifying, inviting, and managing your participation in our marketing activities, such as surveys, lucky draws, and quizzes;

(p)    career transition support services;

(q)    [Job applicants]: assessing and evaluating your suitability for employment in any current or prospective position;

(r)    [Job applicants]: pre-employment screening;

(s)    any other purposes for which you have provided the information; and

(t)    any other incidental business purposes related to or in connection with the above.

  1. With reference to 9(n) and (o), we may communicate such marketing to you through various channels, where applicable, including by email, phone call, text message, SMS, and chat applications (e.g. WhatsApp, Telegram). If you wish to unsubscribe from receiving such marketing communications, please click on the unsubscribe link in the relevant email or message.
  1. We may disclose your personal data to third parties where necessary for the purposes described in clause 9. Where we engage third-party service providers (other companies and individuals) to perform functions on our behalf, they will need access to your personal information needed to perform their functions but may not use it for other purposes.
  1. If you choose to share personal data of other people (such as references for job applicants) with us, it is your responsibility to inform such other people, whose personal data you provide, about the use of their personal data as set out in this Notice.
  1. Our website uses cookies to improve your browsing experience. These cookies are essential for the working of basic functionalities of our website and to help us analyse and understand how you use our website generally, recognize your repeat visits and preferences, as well as to measure and analyse traffic.
  1. These cookies will be stored in your browser only with your consent. By clicking “Accept” on our cookie banner, or if you continue to explore our website without changing your cookie settings, you consent to the use of the cookies on our website. You also have the option to opt-out of these cookies by changing your cookie settings anytime. But opting out of some of the cookies may have an effect on your browsing experience.
  1. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to contract with us) has been terminated or altered in any way, for a reasonable period thereafter.

WITHDRAWING YOUR CONSENT

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  1. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
  1. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 16.
  1. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, usage and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

  1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. We will respond to your request as soon as reasonably possible.
  1. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

PROTECTION OF PERSONAL DATA

  1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, access control, password protection and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
  1. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

  1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
  1. We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up to date, taking into account its intended use. Where possible, we will validate the information provided by you using generally accepted practices and guidelines.

RETENTION OF PERSONAL DATA

  1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
  1. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  1. If your personal data is to be transferred out of Singapore in line with the purposes in clause 9, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Singapore PDPA.

DATA BREACH NOTIFICATION

  1. In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the impact and once assessed that it is a notifiable data breach, we shall report this breach to the Personal Data Protection Commission (PDPC), unless an exception applies. We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. If we are the Data Intermediary, we shall inform our Data Controller immediately without undue delay upon detection of a data breach that may affect them so that they can promptly assess the impact and comply with their own data breach notification obligation.

DATA PROTECTION OFFICER

  1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address: dpo@polwel.org.sg

EFFECT OF POLICY AND CHANGES TO POLICY

  1. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
  1. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Last Updated: 1 August 2025