THE PERSONAL DATA PROTECTION ACT
The Personal Data Protection Act 2012 (No. 26 of 2013) or “PDPA” governs the collection, use and disclosure of personal data by organisations. It contains various obligations relating to the Do-Not-Call Registry (“DNC Obligations”) and the protection of personal data.
Overview of the Personal Data Protection Act (PDPA)
Overview of PDPA’s Data Protection Rules for Individuals
About Do Not Call (DNC) Registry for Individuals
1. Your Personal Data
a) Your name, NRIC, passport or other identification number, personal telephone number(s), personal mailing address, personal email address, personal bank account, credit card information, employment history, education background, income levels;
b) Photos, films, portraits and/or video recordings of you;
c) Information about your use of NVPC’s websites, including cookies, IP addresses, etc.
d) Any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you.
2. Collection of Personal Data
2.1 NVPC may collect your Personal Data in one or more of the following ways when you:
a) visit our premises as CCTV recordings is on for 24 hours;
b) donate or offer your volunteer time through our websites;
c) visit our websites;
d) attend our events, conferences, forums, workshops, talks;
e) register for our services;
f) register with us as volunteers;
g) donate to NVPC;
h) interact with any of our employees, interns, volunteers, board and committee members;
i) request that we contact you, be included in an email or other mailing list;
j) respond to our communications;
k) participate in research and/or surveys conducted by us or our partners/vendors;
l) apply for employment or internship with NVPC;
m) use third party services that give us your Personal Data;
n) submit your Personal Data to us for any other reasons;
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 NVPC may collect, use and/or disclose your Personal Data for the purposes for which you have consented, and where applicable, for the purposes listed below:
3.1.1 Marketing and Advocacy
NVPC may contact you to inform you about NVPC and/or NVPC related organisations products and services, or other information which may be of interest to you. We may also invite you to participate in NVPC events and activities.
3.1.2 Administration and Servicing
In order to administer and service your needs effectively, we will collect, use and disclose your personal data, for any of the following purpose(s):
a) administration of your data, which may include but is not limited to:
i. carrying out your instructions or responding to any enquiries by you;
ii. assessing and processing your requests made to NVPC;
iii. administering your interaction with other third-parties made through NVPC, including donations you make to other charities and offering your volunteer time to other organisations.
b) administration of your profile, which may include but is not limited to:
i. maintenance of your personal data captured in the profile;
ii. carrying out your instructions or responding to any enquiries by you;
c) processing and administering payment, billing, account, benefits/entitlements, credit and reference checks, debt-recovery matters, including but not limited to your employment, internship or volunteer assignment with NVPC;
d) compiling statistics for NVPC and/or industry exercises and studies, to design and improve our products and services for you;
e) compliance monitoring and audit reviews;
f) complying with all applicable regulations, laws and internal policies and procedures;
g) providing general information on product enhancements and services, which are relevant to your needs or policies;
h) investigating fraud, misconduct, any unlawful action or omission, and whether or not there is any suspicion of the aforementioned;
i) archiving, backing-up or destroying personal data;
j) informing you of changes and updates to our services, policies, terms and conditions and other administrative information;
k) corresponding with you, which may disclose certain personal data about you on envelopes and/or packages;
l) subject to applicable law and any other purposes set out in the Terms and Conditions and privacy statements of the activity you have undertaken at NVPC.
3.2 All Personal Data submitted to us should be complete, accurate, true and correct. Failure to do so may result in our inability to provide you with services you have requested and/or to process or administer the Personal Data.
3.3 Where Personal Data is submitted by you concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (in accordance with all applicable data protection legislation, including without limitation the PDPA) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.
3.4 If you have provided us with your Singapore telephone number(s) and have consented to contact by telephone, we may contact you using the number(s), unless you are on the DNC Registry for Individuals.
3.5 You shall consult your parent or guardian before providing us with your Personal Data if you are under the age of eighteen .
4. Disclosure of Personal Data
The disclosure of your personal data may be from NVPC to:
a) our employees, volunteers, interns, board and committee members;
b) NVPC-related organisations;
c) you in the form of personal data you had previously supplied us;
d) Banks, CPF or its agent banks, credit card companies, other financial institutions for the processing of any monies receivable or payable;
e) Vendors engaged by us to perform processes required for the administration of your data or to send marketing material or messages to you;
f) Vendors engaged by us to store and maintain our data and documents (including storage for business recovery purposes);
g) Any regulatory, government and statutory body to comply with applicable, laws or regulation or upon their valid request;
h) Our professional advisers such as auditors and lawyers;
i) Any other party to whom you authorize us to disclose your Personal Data to, including but not limited to your consent specific to the NVPC activity.
Neither NVPC nor any of its officials shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to NVPC and/or any of its officials disclosing.
5. Transfer of Personal Data outside Singapore
Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore, where applicable. We will ensure that any party to whom we transfer your Personal Data outside Singapore provides such Personal Data a standard of protection at least comparable to the protection under the Act.
6. Withdrawal or Change of Consent
6.2 If you withdraw your consent to use or disclosure of your Personal Data, we may not be able to provide certain services to you or service or execute agreements you may have with us. NVPC’s legal rights and remedies are expressly reserved in such event.
7. Access and Correction of your Personal Data
7.1 You may request access to or make corrections to your Personal Data records, by submitting your request to our Data Protection Office at firstname.lastname@example.org.
7.2 If you so request, provided that the request is of a reasonable nature, we will make available, within a reasonable time between 30 and 90 working days, an account of how your Personal Data was generally used or disclosed.
7.3 As you are responsible for providing correct and accurate Personal Data to NVPC, we strongly discourage frivolous, excessive or unreasonable requests for access and correction to Personal Data, which will result in higher administration cost for NVPC. NVPC reserves the right to charge a reasonable administration fee for processing your request.
8. Protection, Policies and Procedures
8.1 To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial policies and procedures to safeguard, secure and/or dispose the Personal Data we collect.
8.2 Notwithstanding the above, you acknowledge that no data transmission over the internet is completely secure and you are transmitting Personal Data over the internet at your own risk.
9. Retention of your Personal Data
We will retain your Personal Data for as long as your use our services and it is necessary required or relevant for business or legal purposes.
On our websites, we may use “cookies” to track information about user frequency, profiles and preferred sites. This information will assist us in improving our websites. You may disable cookies by changing the settings on your browser. However, you may not be able to access certain part(s) of our websites or services.
11. Third-Party Websites