Data Protection Notice
DATA PROTECTION NOTICE FOR DONORS, SERVICE USERS AND VOLUNTEERS
This Data Protection Notice (“Notice”) sets out the basis which Shaw Heritage Arts and Wellbeing Studios Ltd (“we, “us” or “our”) may collect, use, disclose or otherwise process personal data of our prospective service users, service users, service users' authorised representative, donors, volunteers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Collection, use, disclosure or otherwise processing of personal data of our service users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. Shaw Heritage Arts and Wellbeing Studios Ltd will comply with the relevant requirements under the government’s data management policy.
PERSONAL DATA
1. As used in this Notice:
“personal data” means data, whether true or not, about an individual (whether a prospective service users, service users, service users' authorised representative, donors, volunteers or otherwise) 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as nric, fin, work permit and birth certificate, contact information such as residential address, email address or telephone number, nationality, gender, date of birth, marital status, medical history, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) 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 (your “authorised representative”) 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 which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
establishing or managing your relationship with us. This includes:
Where you are a prospective service user,
processing and evaluating your application for our services
Where you are a service user,
providing the services requested by you;
monitoring, evaluating and/or auditing of services provided. This may include an assessment of the quality of the services provided and the effects of the services provided (both in the short and long term, and after you have stopped using the services); and
research related to your personal circumstances or services you used, in particular, for our research entitled (Insert Title of Research Project). We will notify you and obtain your written consent before using your personal data for any specific research project, unless otherwise permitted under the PDPA or other legislation.
Where you are a service user's authorised representative
processing and evaluating the service user’s application for our services
Where you are a donor,
processing your donations and your tax-deduction claims
Where you are a volunteer,
processing and evaluating your suitability to volunteer; and
monitoring, evaluating and/or auditing of services you participated in.
providing you with information on our upcoming events or activities, where you have specifically requested to receive such information;
verifying your identity;
responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
any other purposes for which you have provided the information.
6. We may disclose your personal data:
where such disclosure is required for, or in connection with, the provision of the services requested by you;
to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 5 above for us;
to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations; and
any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
8. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Shaw Heritage Arts and Wellbeing Studios Ltd or another person. In relying on the legitimate interests exception of the PDPA, Shaw Heritage Arts and Wellbeing Studios Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
9. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
Fraud detection and prevention;
Detection and prevention of misuse of services; and
Network analysis to prevent fraud and financial crime, and perform credit analysis.
The purposes listed in the above clause 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 thereafter.
WITHDRAWING YOUR CONSENT
7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email or otherwise in writing to our Data Protection Officer at the contact details provided below. If you are unable to submit your request in writing or if you require any assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
8. 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.
9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position 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 the manner described in clause 7 above.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
11. 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 the ways in which 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 via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
12. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.