LOVING HEART MULTI-SERVICE CENTRE
PERSONAL DATA PROTECTION NOTICE FOR DONORS, SERVICE USERS AND VOLUNTEERS
This notice (“Notice”) sets out the basis which Loving Heart Multi-Service Centre (referred in this Notice as “LHMSC”, “we, “us” or “our”) may collect, use, disclose, store or otherwise process the personal data of:
Service users, referring to prospective or current recipient of benefits provided through us and who is registered with us, including their authorised representative(s);
Donors, referring to individuals who support us in our work through financial or material contribution;
Volunteers, referring to individuals or employees and/or contractors of entities who voluntarily assist us in our work without remuneration;
(each of the above shall be referred to in this Notice as “you” or “your”) in accordance with the Personal Data Protection Act 2012 (“PDPA”). References to LHMSC shall include employees, consultants and volunteers. LHMSC will comply with all requirements under the PDPA with respect to personal data collected, used, disclosed, processed or stored by its employees, consultants and volunteers. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context requires).
This Notice applies to your personal data in our possession or under our control, including personal data in the possession of third-parties engaged by us to collect, use, disclose or process personal data for our purposes.
In certain situations, collection, use, disclosure or other forms of processing your personal data on behalf of government ministries or statutory boards will be required and shall be carried out in accordance with guidelines set out in the government’s data management policy. LHMSC will comply with the relevant requirements under the government’s data management policy.
“Personal data” is data that can be used to uniquely identify an individual. It may be data that is true or untrue, and it also includes data that, when used with other data, can identify an individual. Some examples of personal data which we may collect from you are:
personal particulars (e.g.: name, identification numbers such as NRIC, FIN, work permit, and birth certificate numbers, contact information, nationality, gender, date of birth, marital status;
medical history, employment details and financial information;
information relating to your activities, habits, preferences and interests; and/or
photographs and other audio visual information.
The above categories are not exhaustive.
COLLECTION OF PERSONAL DATA
We generally do not collect your personal data unless it is provided to us voluntarily by you or via an authorised representative who has been duly authorised by you to disclose your personal data to us after:
you (or your authorised representative) have been notified of the purposes for which the personal data is collected; and
you (or your authorised representative) have provided written consent to the collection and usage of your personal data for purposes disclosed in this Notice or by LHMSC.
We may collect and use personal data without consent where it 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.
USE OF PERSONAL DATA
We may collect and use your personal data for any or all 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 or agreed to by you;
enabling our volunteers, consultants, engaged contractors and/or partnering organisations to assist us in providing services requested or agreed to by you;
communicating with you, including providing you information on counselling sessions, exhibitions, workshops or other social activities that you may be interested in;
responding to your queries or feedback;
monitoring, evaluating and/or auditing of quality and completion of services provided; and/or
in emergency situations where LHMSC is of the view that your personal health and safety may be seriously adversely affected. 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, and any other related transactions; and/or
Compliance with charity fundraising and financial regulations.
Where you are a volunteer,
processing your application and evaluating your suitability to volunteer;
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;
screening by government agency, where the role you serve in requires;
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;
any other purposes for which you have provided the information;
transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and/or
any other incidental purposes related to or in connection with the above.
Managing, maintaining and upgrading our infrastructure, systems operations and complying with internal policies and applicable laws;
Improving our service operations, volunteer training and capabilities and contribution to the social service sector of Singapore;
In connection with the performance of our duties and obligations when seeking consultancy and professional advice;
Complying with any authorised requests from local authorities, including regulatory, governmental and law enforcement authorities; and
Conducting audits, due diligence and compliance checks required by our internal polices and applicable laws.
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 4 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.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of LHMSC or another person. In relying on the legitimate interests exception of the PDPA, Loving Heart Multi-Service Centre will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
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; or
Collection and use of personal data on company-issued devices to prevent data loss.
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
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 at the end of this Notice. 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.
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 reply to your request within three (03) business days and process it within fourteen (14) business days of receiving it, up to a maximum of thirty (30) business days in the presence of extenuating circumstances.
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 able to continue our relationship with 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 9 above.
Please note that withdrawing your 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
If you wish to make
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
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 at the end of this Notice. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer. You will be required to prove your identity, and LHMSC reserves the right to deny vexatious and/or frivolous requests.
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. In most straightforward cases, the fees are generally as follows (pages are in A4-size):
Onsite viewing at LHMSC Office: Free
Encrypted PDF file or images, up to 5 pages or images, sent via email: Free
Encrypted PDF file or images, up to 5 pages or images, contained in USB media and self-collected at LHMSC Office: Cost of media + S$20 processing fee
Video footage file, contained in USB media and self-collected at LHMSC Office: Cost of media + S$50 processing fee
Hardcopy, self-collection from LHMSC Office: S$1 per page, minimum of S$5
Hardcopy, via regular mail: S$1 per page, minimum fee of S$5 + postage cost
Hardcopy, via registered mail: S$1 per page, minimum fee of S$30 + registered postage cost
The fees herein are for general reference only, and the fees apply separately per data type (e.g. 1 PDF file + 3 Images = two data types) in a request and per instance of request.
For fees regarding other formats of personal data or modes of access, you can ask to speak to or meet with our Data Protection Officer.
We will respond to your request as soon as reasonably possible. In general, we will reply to your request within thirty (30) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, 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).
PROTECTION OF PERSONAL DATA
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, and web security measures against risks.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While absolute security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer at the contact details provided below.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or our purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : Bernard Lok
Contact No. : 6897 4766
Email Address : email@example.com
Address : 210, Jurong East Street 21, #01-389, Singapore 600210
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.