PDPA Policy

We at [Company] respect the privacy and confidentiality of our clients’ personal data. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Personal Data Protection Act (PDPA) 2012 of Singapore.

We have developed this Data Protection Policy to assist you in understanding how we collect, use, disclose, process and retain your personal data.

1. How We Collect Your Personal Data

The PDPA defines personal data as “data, whether true or not, about an individual who can be identified

  1. from that data; or
  2. from that data and other information to which the organisation has or is likely to have access.”
  3. We collect the personal data of our prospects and clients through the following methods / channels:
    1. When you make payment
    2. When you respond to a marketing call for new product or service
    3. When you call in to request for information or enquiry
    4. When you submit an application form
    5. When you request for technical support
    6. When you wish to preview a product or service
    7. When you send in your job application form
    8. When you sign in as a visitor
    9. When you register as a participant
    10. When you indicate you wish to have follow-up from salesperson
    11. When you sign up for a service
    12. When you leave your contact details
    13. When you respond to a marketing call
    14. When you agree to a site survey

    2. Types of Personal Data We Collect About You

    The types of personal data we collect about you may include:

    • Academic History
    • Criminal Background/Past Offences
    • Education & Professional Qualifications
    • Employment Details & History
    • Family Background & Details
    • Medical Details/Health Information
    • Personal Contact Information
    • Personal Details
    • Photos & Video Footage
    • Purchase Information/History
    • Customer Feedback
    • Site Survey Information

    3. How We Use Your Personal Data

    We use the personal data we have collected about you for one or more of the following purposes:

    • Account payables/receivables
    • Analyse risk and business results
    • Analyse the use of our products, services, and sites
    • Benefits & compensation management
    • Billing and payment processing
    • Business review
    • Carry out our obligations arising from any contracts entered into between you and us
    • Claims & disbursements
    • Comply with legal obligations and regulatory requirements
    • Conduct risk assessment
    • CPF related processing
    • Create, develop, operate, deliver and improve our products and services
    • Customer care and account management
    • Delivery of products and services
    • Detect and protect against error, fraud or other criminal activities
    • Develop new applications, products and services
    • Develop, enhance, market and provide products and services
    • Employee communication
    • Enforce obligations owed to us
    • Enforce terms and conditions of use
    • Enhance customer experience
    • Fulfil legal requirements
    • Fulfil orders and services
    • Fulfil requests for products and services
    • Help improve products and services
    • Income tax returns
    • Internal purposes for accounting, auditing and booking
    • Internal purposes for auditing, data analysis and research
    • Investigate complaints, claims and disputes
    • Manage and improve our business and operations to serve you better
    • Obtain opinions, comments about products and services
    • Pass information about you to our agents and associates to carry out services
    • Payroll processing
    • Personnel management
    • Process and administer employment records
    • Process applications and registration
    • Process contract renewals and upgrades
    • Process payment for products and services
    • Process payment for purchases and transactions
    • Processing & administration of employment records
    • Provide customer service and support
    • Provide information to subsidiaries or partners that perform services for the company
    • Receive personal data from 3rd party to support new contracts
    • Recruitment & selection
    • Respond to inquiries and provide customer services
    • Respond to queries and feedback
    • Sales commissions
    • Send information and updates
    • Staff Appraisals
    • Training & career development
    • Update records in our database

    4. Who We Disclose Your Personal Data To

    We disclose some of the personal data we have collected about you to the following parties or organisations outside ISS Facility Services Private Limited:

    • Accounting Firms
    • BATU –Trade Union
    • BCA – Building and Construction Authority
    • Branch Office(s)
    • Complainants
    • Credit Reporting Agencies
    • Customers / Clients
    • Data Analysis & Analytics Firms
    • Database Companies
    • Debt Collection Agencies
    • Delivery Services
    • Email Vendors
    • EMAS - Environmental Management Assn of Spore
    • Employees / Staff
    • Government accredited training centres
    • Head Office
    • Information Technology Service Providers
    • Insurance Companies (Group Insurance for Employees)
    • Legal Services
    • Mailing Houses, Freight and Courier Services
    • Marketing & Communications Agencies
    • Medical Practitioners
    • MOH – Ministry of Health
    • MOM – Ministry of Manpower
    • NEA - National Environment Agency
    • Newspapers & Publications
    • Next-of-Kin / Guardians
    • Other Contracted Service Providers
    • Patients
    • Payroll Processing Services
    • Print Processing Services (e.g. statements)
    • Recruitment Agencies
    • Survey Firms
    • Visitors

    5. How We Manage the Collection, Use and Disclosure of Your Personal Data

    We take our responsibilities under the PDPA seriously. We are committed to implementing policies, practices and processes for data protection that comply closely with the PDPA obligations.

    a. Obtaining Consent:

    Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purpose.
    Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you enter into a sales agreement.

    b. Third-Party Consent:

    If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.

    c. Withdrawal of Consent:

    If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted.

    Your request for withdrawal of consent can take the form of an email or letter to us.

    6. Accessing and Making Correction to Your Personal Data

    You may write in to us, based on reasonable grounds, to find out how we have been using or disclosing your personal data. We are obligated under the PDPA to allow you access to your personal data of the past one year, and to make any correction if there is any error or omission. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will try to respond to your request within 30 days. By which time we will give you an estimate of how long it is going to take to retrieve all the relevant data, and how much we will charge you for processing the request.

    7. Accuracy of Your Personal Data

    We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we will do a verification exercise for you to update us on any changes to your personal data. If you are a client or customer, it is important that you update us if there are any changes in your personal information such as your home address.

    8. Protection of Personal Data

    We have implemented an Information Security Policy that governs how personal data and confidential information are protected within our organisation. We will take the necessary security arrangements to protect your personal data that is under our charge or control to prevent unauthorised access, collection, use, disclosure, or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
    External data intermediaries who process and maintain your personal data on our behalf will be bound by contractual data security arrangements we have with them.

    9. Retention of Personal Data

    We will not retain any of your personal data under our charge or control when it is no longer necessary for any business or legal purposes. We have a Document Retention Policy that spells out how long we ought to retain each type of confidential document or personal data. Certain retention periods are based on statutory or regulatory requirements.
    We will ensure that your personal data that no longer has any business or legal use will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in databases.

    10. Transfer of Personal Data

    If there is a need for us to transfer your personal data to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.

    11. Do-Not-Call (DNC) Provisions and Telemarketing Activities

    We do not make telemarketing call to promote our services.

    12. Contacting Us

    If you have any questions about our collection, use, and/or disclosure of your personal data; feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer using the Ticket feature above.

    Any query or complaint should include, at least, the following details:

    • Full name and contact information of the data subject
    • Brief description of the query or complaint

    We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.

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