DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis whichSouth Central Community Family Service Centre Limited(“SCC”, “we”, “us”, or “our”)may collect, use, disclose or otherwise process personal data of persons in accordance with the applicable personal data protection laws and regulations. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations we have engaged in collecting, using, disclosing or otherwise processing personal data for our purposes.
1. Personal Data
1.1. As used in this Notice:
1.1.1. “person” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may enter or has entered a contract with us for the supply of any products or services by us, or (c) has submitted a job or internship application with us; and
1.1.2. “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.
1.2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, education background, and information about your usage of and interaction with our website.
1.3. Other terms used in this Notice shall have the meanings given to them in the Singapore Personal Data Protection Act (where the context so permits).
2. Collection, Use and Disclosure of Personal Data
2.1. We may collect personal data from our members (clients/beneficiaries), community partners and members, volunteers, donors, board members, employees, contractors, and other individuals, such as job applicants. We would only collect, use and disclose data that (a) has been provided to us voluntarily by you directly or via a third party (your “authorised representative”) which you have duly authorised to disclose your personal data to us after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) 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 for which you have not been notified (except where permitted or authorised by law).
2.2. These personal data may be furnished to us in forms filled out by you, face-to-face, via email, text messages (WhatsApp, SMS), or telephone conversations. We may also keep a record of any contact you have with us. These data will be collected only for the purpose(s) we stated when we gather your personal data.
2.3. The personal data collected may be used for any or all the following purposes:
2.3.1. to provide our services or programmes to you.
2.3.2. as part of our business operations.
2.3.3. for board member recruitment and appointment purposes
2.3.4. for volunteer recruitment and appointment purposes
2.3.5. for job application and recruitment purposes.
2.3.6. for donor management purposes.
2.3.7. for billing and reporting, such as for invoicing and account management purposes.
2.3.8. for follow-up action regarding any complaints, feedback, queries or requests received via our website or any other communication channels; and
2.3.9. assisting in law enforcement and investigations conducted by any governmental or regulatory authority.
2.4. We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law, such as during the following situations:
2.4.1. to respond to an emergency that threatens your life, health and safety or of another individual and
2.4.2. necessary in the national interest for any investigation or proceedings.
2.5. We may disclose your personal data:
2.5.1. with your consent, where such disclosure is required for performing obligations during or in connection with our provision of the programmes or services requested by you.
2.5.2. to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your personal data); or
2.5.3. with your consent to third-party service providers, agents and other organisations we have engaged to perform any of the functions listed in paragraph2.3 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
2.6. You have the right of choice regarding the collection, usage and/or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be able to perform our obligations as stated in this notice. You have the right to object to the processing of your personal data and withdraw your consent in the manner described below.
2.7. If you choose not to provide us with your personal data for the purposes listed in paragraphs2.3 and2.4, you may submit a request in writing or via email to our Data Protection Officer at the contact details provided below or indicate in the personal data collection form submitted to us (if any). By choosing not to provide us with your personal data, depending on our relationship, we may not be able to provide services to you or process your job application. Depending on the complexity of the request and its impact on our relationship with you, we will not collect or, within 30 days of our receipt of your request, cease using and/or disclosing your personal data in accordance with your request.
2.8. The purposes listed in paragraph2.3 may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way for a reasonable period after that (including, where applicable, a period to enable us to enforce our rights under any contract with you).
2.9. If we receive unsolicited personal data via email or any other communication channel, we will not retain it and will securely dispose of it immediately.
3. Withdrawal of Consent
3.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw your consent and request us to stop 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.
3.2. 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. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect.
3.3. While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able 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 paragraph3.1 above.
3.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Access to and Correction of Personal Data
4.1. 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 how 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.
4.2. We will respond to your request as soon as reasonably possible. Before we accede to your access or correction request, we may need to verify your identity by checking your identification document and the legitimacy of your request. Should we not be able to respond to your request within thirty (30) days after receiving your request in writing (including both electronic and non-electronic methods), we will inform you in writing within thirty (30) 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).
4.3. If your request relates to personal data that we are processing on behalf of another organisation, we will forward your request to the relevant organisation for their necessary action.
4.4. A reasonable fee may be charged for an access request. We will inform you of the cost before processing your request.
5. Protection of Personal Data
5.1. 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 and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to authorised third parties and agents only on a need-to-know basis.
5.2. If there is a need to disclose your Personal Data to third parties in line with the purposes mentioned in paragraph2.5, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.
5.3. However, no method of transmission over the Internet or method of electronic storage is entirely secure. While security cannot be guaranteed, we strive to protect the security of your personal data and are constantly reviewing and enhancing our information security measures. In the event of a personal data breach, we will endeavour to notify the affected parties no later than three calendar days from when we become aware of the breach.
6. Accuracy of Personal Data
6.1. We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
6.2. We generally rely on personal data provided by you (or your authorised representative). To ensure that your personal data is current, complete, and accurate, please update us if your personal data changes by informing our Data Protection Officers at the contact details provided below.
7. Retention of Personal Data
7.1. We may retain your personal data for as long as it is necessary to fulfil the purpose(s) for which it was collected or as required or permitted by applicable laws.
7.2. We dispose of or destroy such documents containing your personal data securely when the retention limit is reached and it is reasonable to assume that their retention no longer serves the permitted purpose.
8. Cross-Border Transfers of Personal Data
8.1. Unless for business-related needs, we generally do not transfer your personal data to other jurisdictions. However, if we do so, we will obtain your consent for the transfer. 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, including agreeing with the receiving party to accord similar levels of data protection as those in Singapore.
9. Data Breach Notification
9.1. In the event of a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data, we shall promptly assess the impact and, if appropriate, report this breach within three 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 inform other relevant regulatory agencies where required.
10. Data Protection Officer
10.1. You may contact our Data Protection Officer if you have any enquiries, feedback, or complaints regarding our personal data protection policies and procedures, if you wish to make any requests, or if you believe the information we hold about you is incorrect or outdated.
11. You may contact our Data Protection Officer via the following contact information:
Telephone No:6461 9200
Email:dpo@sccfsc.org.sg
Address:Blk 5 Delta Avenue, #01-09, Singapore 160005
12. Modifications
12.1. We may revise this Notice at any time without prior notice. Your continued use of our services and/or products constitutes your acknowledgement and acceptance of such changes.
Effective: 1 November 2024