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 collected by us in the course of acting on behalf of a public agency may be exempted from the PDPA.
- As used in this Policy, personal data means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Data intermediary in this Policy means an organisation which processes personal data on behalf of another organisation (the data controller).
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number, nationality, employment information, NRIC, passport or other identification number, gender, date of birth, marital status, mailing address, photographs and other audio-visual information, financial information and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
- 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
- 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).
- 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 17. 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).
- In accordance with the Advisory Guidelines on the Personal Data Protection Act for NRIC and other National Identification Numbers, we will generally not collect, use or disclose NRIC numbers (or copies of NRIC). We will do so only in the following specific circumstances:
- When collection, use or disclosure of NRIC numbers (or copies of NRIC) is required under the law (or an exception under the PDPA applies); or
- Collection, use or disclosure of NRIC numbers (or copies of NRIC) is necessary to accurately establish or verify the identity of the individual to a high degree of fidelity.
- In accordance with these Advisory Guidelines, we may collect, use or disclose NRIC numbers (or copies of NRIC) without the individual’s consent if it is required by law. In such instances, we may notify the individual of the purpose for the collection, use or disclosure as the case may be.
- 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.
- 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 or where it is necessary for any investigations or proceedings. 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.
- We may collect and use 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) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(c) verification and identification purposes, including verifying your identity when you attend the assessments conducted by us;
(d) enabling the Police Licensing Regulatory Department to carry out the necessary licensing for the private security industry;
(e) any other purposes for which you have provided the information; and
(f) any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
(b) where we employ 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.
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- Any unsolicited personal data received by us will not be retained and will be deleted as soon as practicable. If received by telephone, these will not be recorded.
- 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
- 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.
- 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. In general, we shall seek to process your request within ten (10) business days of receiving it.
- 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 17.
- 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
- 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.
- 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.
- We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) calendar days. Should we not be able to respond to your request within thirty (30) calendar days after receiving your request, we will inform you in writing within thirty (30) calendar days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
- 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.
- 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
- 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.
- 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
- 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.
- 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
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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 PDPA.
DATA BREACH NOTIFICATION
- 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 within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required. 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
- 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: firstname.lastname@example.org
EFFECT OF POLICY AND CHANGES TO POLICY
- 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.
- 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: 9 June 2022.