DATA PROTECTION NOTICE

This Data Protection Notice sets out the basis which Bethel Community Services may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

  1. As used in this Notice: “personal data” means data, whether true or not, about a client and/or service user 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. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
    1. your name
    2. identification information such as your NRIC number/FIN number/ Passport No.
    3. contact information such as your email address or telephone number
    4. your residential address,
    5. your nationality,
    6. gender,
    7. date of birth,
    8. marital status,
    9. photographs and other audio-visual information,
    10. employment, educational, health, financial and other information.
  1. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
  1. For Non-Clients (partners, donors, volunteers and potential employees), Bethel Community Services will keep your personal data confidential and will not disclose to any related or unrelated third parties, unless otherwise required or permitted by law.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  1. 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).
  1. We may collect and use your personal data for any or all of the following purposes:
    1. As a service user (of our services):
      1. Providing the services requested by you;
      2. Monitoring, evaluating and/or auditing of services provided. This may include the publication of your testimonials of our services onto social media platforms.
    2. As a donor/sponsor:
      1. For processing your donations
      2. For tax deduction claims
      3. Verification purposes in relation to your donations
    3. As a volunteer:
      1. To process and assess your suitability in volunteering
      2. Assessing, monitoring, evaluating and/or auditing of the services that volunteers have participated in.
    4. As a beneficiary/client:
      1. Bethel Community Services is dedicated to keeping your personal data confidential.
      2. Depending on the nature of the beneficiary/client engagement, BCS may disclose your personal data to the government, law enforcement authorities or any other related third party (e.g. another government agency or SSO) when:
        1. It is necessary in the interest of the individual (such as referrals for external services or application of schemes administered by public agencies);
        2. Indication of assessment of harm and risk to self or others, where disclosure is necessary to safety and protection of life;
        3. It is used for evaluative purposes (approval of grant for social and financial assistance, the delivery of appropriate health services under any scheme administered by a public agency);
        4. The disclosure is required by law; for any necessary investigations or proceedings and/or;
        5. The disclosure is permitted under any of the statutory exemptions under the PDPA.
    5. Providing you with information on our events and activities, where you have given permission/ requested to receive such information.
    6. verifying your identity;
    7. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
    8. establishing and/or managing your relationship with us;
    9. processing payment or credit transactions;
    10. 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;
    11. any other purposes for which you have provided the information;
    12. 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
    13. any other incidental purposes related to or in connection with the above.
  1. We may disclose your personal data:
    1. where such disclosure is required for performing obligations in the course of, or in connection with our provision of the goods or services requested by you; or
    2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed above in Clause 6.
  1. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).
  1. Bethel Community Services reserves the right to not provide/discontinue our services should we find service users/ clients be providing inaccurate and/or insufficient information in relation to the services provided.

WITHDRAWING YOUR CONSENT

  1. 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 in writing, or by email. You may withdraw 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 at dpo@bethelcs.org.sg.
  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.
  3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature of the withdrawal, the withdrawal of your consent may result in us being unable to provide, or continue to provide our services to you and/or your family members.
  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 by law.

ACCESS TO AND CORRECTION OF PERSONAL DATA

  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 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 in writing or via email to our Data Protection Officer at dpo@bethelcs.org.sg.
  2. 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.
  3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) working days after receiving your request, we will inform you in writing within thirty (30) working 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. You should ensure that all data provided to us is complete, true and accurate. Failure to do so may result in the inability to provide or continue to provide our services to you and/or your family.

PROTECTION OF PERSONAL DATA

  1. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While 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

  1. 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 in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

  1. 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 do not retain Personal Data for a period of longer than five years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. For unsuccessful applicants, we will retain your Personal Data for no longer than three years for the purposes of evaluating your suitability for future job openings, unless you inform us otherwise.
  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
  3. 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 business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  1. 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

  1. 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:

    Data Protection Officer
    Bethel Community Services
    Blk 114 Aljunied Ave 2
    #03-75
    Singapore 380114

    Email: dpo@bethelcs.org.sg
    Telephone: 6744 7422

EFFECT OF NOTICE AND CHANGES TO NOTICE

  1. 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.
  2. 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.

Effective date : [9 September 2019]
Last updated : [9 September 2019]