SPD recognises its obligations under the Personal Data Protection Act 2012 (“PDPA”) and this Privacy Statement is to help you understand how SPD and its satellite centres, (“SPD“, “we“, “us”, or “our”) collects, uses, discloses and process the personal data you have provided to SPD, as well as to assist you in making an informed decision before providing us with any of your personal data.
SPD recognises the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.
In this Privacy Statement, any reference to “you” shall include the legal guardian of SPD’s client who is a minor or a person who is not legally capable of managing his affairs.
Personal Data in this Privacy Statement includes any information which identifies you such as your name, any type of identifier, telephone numbers, address, email address, image, photograph and any other information relating to you, which you have provided to us.
Purposes for Which We Process Your Personal Data
The purposes (“purposes”) for which SPD processes Personal Data include the following as may be applicable to you:
- to process, administer, facilitate, maintain and manage your relationship with SPD as a member, volunteer, programme participant, beneficiary, customer, donor and/or employee;
- to provide you with and administer the services you have requested and maintaining our relationship with you;
- to provide you with information and materials on SPD’s activities, products, programmes and services and those of third parties with whom SPD may collaborate;
- for communications pertaining to needs, donations and sale of products and services;
- to conduct research, surveys and for statistical analysis with the aim of reviewing, developing and improving our products, programmes and services; and
- to help plan and develop strategic direction for the future delivery and support of our services and programmes.
Collection of Personal Data
Generally, we collect Personal Data in the following ways:
- when you submit any forms, including but not limited to application, registration, assessment and survey forms, whether in paper or electronic mode;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services, make a donation or purchase any of our products;
- when you interact with our staff, including customer service officers, marketing representatives and agents, for example, via telephone calls, letters, fax, face-to-face meetings and email;
- when you interact with us and use our services provided online and through other technology platforms, such as websites, and apps, including when you establish any online accounts with us;
- when your image is captured by us via CCTV cameras while you are within our premises or via photographs or videos taken by us or our representatives when you attend events hosted by us;
- when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
- when you submit an employment application or when you provide documents or information including your resume and CVs in connection with any purpose;
- when we receive your Personal Data from collaborating entities, business entities, public agencies, your employer, your training institutions, referral agencies and individuals and other third parties;
- when you use our electronic services, or interact with us via our websites or use services on our websites;
- when we seek information from third parties about you in connection with your relationship with us, including job applications or application to be a representative, for example, from your ex-employer and the relevant authorities;
- when you register for our events or promotions, purchase a product or service; and
- when you submit your Personal Data to us for any other reasons.
We generally do not collect your Personal Data unless 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 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 given consent to the collection and use of your Personal Data for those purposes. We may collect or use Personal Data without consent where it is permitted or required by the PDPA or other laws.
Please note the following:
- If you provide Personal Data relating to a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes listed above.
Accuracy of Data
You should ensure that all Personal Data (whether that of your own or of a third party) submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you (or such third party) with products and services you (or such third party) have requested.
You should update us in a timely manner of all changes to the information provided to us. We will make reasonable efforts to ensure your Personal Data is accurate and complete and up to date.
If you do not wish the cookies in our website to collect information about you (for example, store your preferences and record session information), you can adjust settings on your browser so that you will be notified when you receive a cookie. Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings on your browser. However, by doing so, you may not be able to see certain functions or enter part(s) of our websites.
To Whom We May Disclose Your Personal Data
SPD will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to any applicable law, we may disclose Personal Data for any of the purposes specified above to:
- our trusted partners, third party service providers, collaborating entities, agents, independent contractors or providers of professional services who work with us to or on our behalf provide and deliver services to support SPD’s programmes, services, and operations and stipulate their compliance with data protection laws;
- any person to whom disclosure is allowed or required by law, regulation or any other applicable instrument;
- any court, tribunal, regulator (including national and/or international regulator), enforcement agency, exchange body, tax or other authority where we are required to do so by applicable law and/or regulation; any authority or regulator; any directive, order or request of any authority or regulator; or any agreement with a regulator or an authority;
- relevant government authorities, ministries, statutory boards and agencies; and
- any other party to whom you authorise us to disclose your Personal Data to.
You may in writing withdraw your consent given for any or all purposes set out in this Privacy Statement by giving us reasonable notice. If you withdraw your consent to any or all of the purposes, SPD may not be in a position to continue to provide our services to you or to your family members. Given this, SPD has the right to consider your withdrawal a termination by you of any contractual relationship which you may have with us with its consequential effects.
Personal Data may be transferred to, or stored at, a location outside of Singapore and where we do so, we will ensure that the external organisation provides a standard of protection to the Personal Data so transferred that is comparable to the protection under the PDPA.
The security of your Personal Data is important to us. SPD has put in place the necessary technical and organisational security measures to safeguard your Personal Data. Some of the ways we protect Personal Data include external and internal premises security, restricting access only to authorised persons who need it to perform their day to day functions, and maintaining technology products to prevent unauthorised computer access or damage to electronically stored information, such as requiring identifiers, passwords, firewalls and anti-virus software.
We may retain your Personal Data for so long as it is necessary for us to do so, having regard to the uses described in this Privacy Statement or as required or permitted by applicable laws.
If we were already in possession of your Personal Data prior to 2 July 2014, we may have been using your Personal Data to provide information of SPD’s services and appeals for support in SPD activities and donation drives, sale and promotion of products.
Contacting Us and Opt-Out Information
- have questions or comments about our Privacy Statement;
- wish to make corrections to any personal identifiable information you have provided;
- wish to request a copy of the Personal Data processed in relation to you;
- want to opt out from receiving future marketing promotions from SPD and/or third parties which we are associated with,
please the Data Protection Officer, SPD.
SPD is allowed by law to charge you a fee for a copy of your Personal Data. Please make all requests in writing and provide us with evidence of your identity. For opt out, please send a clearly worded email.
This Privacy Statement is governed by the laws of Singapore. You consent to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Privacy Statement.
Updates to This Privacy Statement
SPD may amend this Privacy Statement at any time to ensure that it is consistent with any developments to the way SPD uses Personal Data or any changes to the laws and regulations applicable to SPD. We will make available the updated Privacy Statement on our website. All communications, transactions and dealings with SPD shall be subject to the latest version of this Privacy Statement in force at the time.
Last Updated: 5 November 2018