It is Crestar Learning Centre (“CLC”)’s policy to comply with all applicable primary and data protection laws in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”). CLC recognises the importance of the personal data that parents and/or guardians and their children and relevant public (collectively referred to as “the Public”) have entrusted to organisation. It is CLC’s responsibility to properly manage, protect and process personal data. Should the Public at any time, have any queries relating to personal data, they may contact CLC’s Data Protection Officer (“DPO”) at firstname.lastname@example.org.
INTRODUCTION TO THE PDPA
- “Personal Data” as defined under the PDPA refers to data collected, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organisation has or is likely to have access.
- The Public will be notified of the purposes that personal data is collected, used, disclosed and/ or processed and obtain consent, unless an exception under the law permits that no prior consent is needed by CLC to collect and process personal data.
PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
The personal data which CLC collect may be collected, used, disclosed and/or processed for various purposes and circumstances, including:
- Assessing the Public’s suitability for the course enrolment;
- Providing information and/or updates related to CLC’s courses, products and services, benefits, promotions and events by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- Administering and processing of any payments, fee adjustments, insurance claims, refunds and waivers related to courses, products, services and/or trainings requested;
- Facilitating student-related and/or enrolment related matters such as tracking and managing attendance and academic performances, airport pick-up/transportation, accommodation arrangements, application and renew of student passes;
- Responding to any enquiries, requests or complaints and resolve any issues and disputes which may arise from any relationships with CLC;
- Maintaining and updating of centre records;
- Conducting market research or surveys, marketing trend analysis of customer data in relations to CLC product and/or services;
- Sharing of personal data with CLC’s business or corporate partners for development of courses, products and/or services or launch marketing campaigns;
- Sharing of personal data with financial institutions for the purpose of processing payment instructions, applying and obtaining credit facility(ies), if necessary;
- Audit, risk managements and security purposes;
- Detecting, investigating and preventing fraudulent, prohibited or illegal activities and analysing and managing of commercial risk;
- Enabling CLC to perform our obligations, transfer, assign and enforce our rights, interests and obligations under any agreements or documents the company is a party to/entered into;
- Meeting or complying with any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to CLC;
- Enforcing or defending CLC and the Public’s rights, and to comply with obligations under the applicable laws, legislations and regulations;
- Other purposes which CLC notifies at the time of obtaining Public’s consent; and/or
any purpose which are reasonably related to the aforesaid, (collectively referred to as “Purposes”);
- As the purpose for which CLC may or will collect, use, disclose or process your personal data depends on the circumstances at hand, such purpose may not appear above. However, CLC will notify the Public of such other purpose at the time of obtaining the consent, unless processing of the Public’s personal data without their consent is permitted by the PDPA or by law.
SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
CLC respects the confidentiality of the personal data the Public has provided. CLC will not disclose the Public’s personal data to third parties without first obtaining consent to do so. However, there are situations that CLC may disclose the Public’s personal data to third parties without first obtaining the Public’s consent including, without limitation, the following:
- Cases in which disclosure is required or authorized based on the applicable laws and/or regulations;
- Cases in which the purpose of such disclosure is clearly in the Public’s interests, and if consent cannot be obtained in a timely way;
- Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of the Public or another individual;
- Cases in which the disclosure is necessary for any investigation or proceedings;
- Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of law enforcement agency or a person if a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- Cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
- Where such disclosure without the Public’s consent is permitted by the PDPA or by law
The instances listed above are not intended to be exhaustive. For more information, please visit https://sso.agc.gov.sg/.
In the event where CLC discloses the Public’s personal data to third parties with the Public’s consent, CLC will employ our best efforts to ensure protection of the Public’s personal data.
ACCESS AND CORRECTION
The Public may request to update the personal data in CLC’s records by submitting a written request to the DPO through email or letter. For a request to update personal data, once CLC has sufficient information from the Public, CLC will:
- Provide or correct the Public’s relevant or personal data within 30 days. If CLC is unable to do so within the said 30 days, CLC will notify the Public of the soonest practicable time within which correction can be made. (Note: The PDPA exempts certain types of personal data from being subject to the Public’s correction request as well as provides for situation(s) when correction need not be made by CLC despite the Public’s request); and
- Send the corrected personal data to organisations to which the personal data was disclosed by CLC within a year before the date the correction was made, unless that the other organisation does not need the corrected personal data for any legal business purpose. Though, CLC may, if the Public gives consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by CLC within a year before the date the correction was made.
REQUEST TO WITHDRAW CONSENT
- The Public may withdraw their consent for the collection, use and/or disclosure of their personal data by submitting their request to CLC’s DPO through email or letter.
- CLC will process the Public’s request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose the Public’s personal data.
- However, the Public’s withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that CLC will not be able to continue with the existing relationship with the Public and the contract that the Public has with CLC will have to be terminated.
MANAGEMENT OF DATA (ACCURACY, COMPLETENESS, PROTECTION AND RETENTION)
- CLC will take reasonable efforts to ensure that the Public’s personal data is accurate and complete. CLC will not be responsible for relying on inaccurate or incomplete data arising from the Public not updating CLC of any changes in their personal data that was initially provided.
- CLC will also put in place reasonable security arrangements to ensure that the Public’s personal data is adequately protected and secured. However, CLC cannot assume responsibility for any unauthorized use of the Public’s personal data by third parties.
- CLC will also put in place measures such that the Public’s personal data in our possession or under CLC’s control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
- If the Public’s personal data is to be transferred out of Singapore, CLC will comply with the PDPA in doing so. CLC will take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that is in-line with the requirements under the Act.
The Public may contact CLC’s DPO through email or letter if they have any complaints or grievances with regards to handling of personal data or CLC’s compliance with the PDPA:
UPDATES ON DATA PROTECTION POLICY
- As part of CLC’s efforts to ensure that CLC properly managed, protect and process the Public’s personal data, CLC will be reviewing our policies, procedures and process from time to time.
- CLC reserves the right to amend the terms of this Data Protection Policy at CLC absolute discretion. All amended Data Protection Policy will be posted on CLC website.
- The Public is encouraged to visit CLC’s website from time to time to ensure that they are well informed of CLC’s latest policies in relation to personal data protection.
Data Protection Officer
Crestar Learning Centre
87 Marine Parade Central, #04-301