THE MALAY HERITAGE FOUNDATION LTD
IT POLICY AND CYBERSECURITY MEASURES
The Malay Heritage Foundation Ltd (hereinafter referred to as “MHF”) takes its responsibilities under the Personal Data Protection Act 2012, Singapore (“PDPA) seriously. We recognise the importance of safeguarding the personal data you have provided us and will responsibly manage, protect and process your personal data.
This Data Protection Policy is aimed at helping you understand how we collect, use, disclose and/or process the personal data you have provided us. This is to assist you in making an informed decision before providing us with any of your personal data.
Please contact our Data Protection Officer (the “DPO”), if you have any wueries on this policy or any other queries in relation to how we manage, protect and/or process your personal data at tel : 62995503 or email to firstname.lastname@example.org
1 INTRODUCTION TO THE PDPA
1.1 “Personal data” is defined under PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access
1.2 MHF will collect personal data in accordance to the PDPA either directly from you or your authorised representatives and/or through our third party service providers (e.g surveys
1.3 MHF will notify you on the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your concent for the collection, use, disclosure and/or processing your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, which include but are not limited to:-
a. Communicating with you on our enquiries;
b. Sending you invitations and promotional information and materials relating to our programmes (such as workshops, public talks, seminars, etc), events, activities and publications under MHF or third party service providers, agents, affiliates, partners or related agencies and/or corporations;
c. Administrative matters and/or processing your sign-ups/ registrations for our programmes (such as workshops, public talks, seminars, etc), events and activities, mailing lists, etc;
d. Manage your donations and/or updating your information for the relevant government agencies such as the IRAS, Commissioner of Charities, etc;
e. Conducting market research and customer satisfaction survey on our our programmes (such as workshops, public talks, seminars, etc), events and activities;
f. Processing your data for statistical analysis to better understand our clients and supporters base and
g. Any other purposes that we notify you of at the time of obtaining your consent
(the above collectively are known as the “Purposes).
As the purposes for which MHF may/will collect, use, disclose or process your Personal data depends on the circumstances at hand, such purposes may not appear above. However, MHF will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA and by law.
2.2 Should MHF require to disclose your personal data to a third party service providers, agents, affiliates, partners or related agencies and/or corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes, MHF will make known any such disclosures to you for your approval and opt-in. In any such cases, the disclosure will be for these a third party service providers, agents, affiliates, partners or related agencies and/or corporations, and/or other third parties to process your personal data on our behalf or otherwise, for one or more of the above-stated Purposes.
3 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 MHF respects the confidentiality of the personal data you have provided to us. As such, MHF will not disclose your personal data to third parties without first obtaining your consent permitting us to do so.
3.2 However, please note that MHF may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:-
a. cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
b. cases in which the purpose of such disclosure is clearly in your interest, and if consent cannot be obtained in a timely manner;
c. cases in which the disclosure is necessary to respond to an emergency which threatens the life, health, safety or yourself or another individual;
d. cases in which the disclosure is necessary for any investigation and/or court proceedings;
e. cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of a written authorisation signed by the Head or Director of that law enforcement agency or a person of similar rank, certifying that personal data is necessary for the purposes of the functions or duties of the officer;
f. cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
g. where such disclosure without your consent is permitted by PDPA or by law.
3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. Should you require more information, kindly refer to the Second, Third, and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You may request to access and/or correct the personal data currently in MHF’s possession or control by submitting a written request to MHF. Please provide MHF with sufficient information so as to confirm your identity, as well as details on the nature of your request to email@example.com.
4.2 For a request to access personal data, once MHF receives sufficient information from you to deal with the request, MHF will seek to provide you with the relevant personal data within 30 days. Note that the PDPA exempts certain types of personal data from being subject to your access request.
4.3 For a request to correct personal data, once MHF receives sufficient information from you to deal with the request, we will:-
a. correct your personal data within 30 days.
b. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
c. MHF may, if you so consent, sent the corrected personal data only to specific organisations to which personal data is disclosed to us with your prior consent, within a year before the date the correction was made.
5 REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in MHF’s possession by submitting your request to firstname.lastname@example.org or by opting out from our mailing lists via our electronic direct mailers.
5.2 MHF will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to use your personal data, it may mean that MHF will not be able to continue with your existing relationship with us.
6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 MHF will made reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by MHF to make a decision that affects you. However, this means that you must update MHF of any changes to your personal data that you had initially provided us with. MHF will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
6.2 MHF will also put in place, reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any authorised access, collection, use, disclosure, copying, modification, leakages, damage and/or alteration of your personal data. However, MHF cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 MHF will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that:
a. the purpose for which that personal data was collected in no longer being served by the retention of such personal data; and
b. retention is no longer necessary for any other legal or business purposes.
6.4 Where your personal data is to be transferred out of Singapore, MHF will comply with the PDPA in doing so. In this regard, this includes obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with personal data transfer or permitting the personal data transfers without such a contract if the PDPA or law permits MHF to.
7 COMPLAINT PROCESS
7.1 Should you have any complaint or grievance regarding how MHF is handling your personal data or about how MHF is complying with the PDPA, please contact us with details of your complaint or grievance via:-
a. Telephone number: +65 6299 5503
b. Email: email@example.com (Please attention it to the ‘Data Protection Officer’)
c. Address: The Malay Heritage Foundation Ltd 85 Sultan Gate Singapore 198501 (Attention: Data Protection Officer)
8 UPDATES ON DATA PROTECTION POLICY
8.1 As part of MHF efforts to ensure that your personal data is properly managed, protected and processed, MHF will review its policies, procedures and processes periodically.
8.2 MHF reserves the right to amend the terms of this Data Protection Policy at the company’s discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at www.warisanSG.org
8.3 You are encouraged to visit the website mentioned in 8.2 from time to time to ensure that you are well-informed of our latest policies in relation to data protection.
Approved as at: 19 July 2014