GENERAL Data Protection Policy
We at RSH (Singapore) Pte Ltd (“RSH”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We recognise the importance of safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at 6746 6555 or email email@example.com.
1.1 “Personal Data” is defined under PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
1.2 We will collect your personal data in accordance with the PDPA either directly from you or your authorised representatives, and/or through our third party partners (e.g. banks, organisations or survey companies). We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.3 The type of personal data we collect include, but are not limited to your: name, identification number (NRIC/FIN), address, contact number and email address. We may also collect other information such as your income level, occupation as well as interests for purposes of understanding our customers better.
2 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, which include but are not limited to:
(a) Communicating with you on your enquiries, and/or sending you marketing, advertising and promotional information and materials relating to products; events; promotions and/or services that we, our partners and/or third party organisations with whom we are collaborating, may be selling or marketing.
(b) Administrative matters on your purchases, managing your membership and/or processing your sign-ups/registrations for events, activities, mailing lists, contests, etc.
(c) Conducting market research and customer satisfaction surveys; and
(d) Any other purposes that we notify you of at the time of obtaining your consent. (collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.2 In order to conduct our business operations more smoothly and to fulfil the above-said
Purposes, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
3 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) 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 that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to process your request. Hence, please submit your written request to firstname.lastname@example.org.
4.2 For a request to access personal data, once we have sufficient information from you to process the request, we will seek to provide you with the relevant personal data within 15 working days. Where we are unable to respond to you within the said 15 working days, we will notify you of the soonest possible time within which we can provide you with the information requested.
4.3 For a request to correct personal data, once we have sufficient information from you to process your request, we will correct your personal data within 15 working days. Where we are unable to do so within the said 15 working days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.
4.4 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we may be charging. Please note that we are not required to respond to or process your access request unless you have agreed to pay the fee.
5 REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to email@example.com and using the online form set out therein.
5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
5.3 Depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by RSH to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized 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.
6.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7 FEEDBACK PROCESS
7.1 If you have any feedback regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your feedback.
7.2 Please contact us through one of the following methods with your feedback:
(a) Singapore telephone number: +65 67466555
(b) E-mail: firstname.lastname@example.org (Attention it to the ‘Data Protection Officer’)
(c) Office address: 190 Macpherson Road, Level 7, Singapore 079914 (Attention it to the ‘Data Protection Officer’)
7.3 We will certainly strive to deal with any feedback that you may have speedily and fairly.
8 UPDATES ON DATA PROTECTION POLICY
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at www.royalsportinghouse.com/privacy.
8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Upon your request and subject to applicable laws, we will provide you with (i) your personal data that is in our possession or under our control; and (ii) information about the ways in which your personal data may have been used or disclosed by us in the past year.
To make a personal data access request, please complete a Personal Data Access/Correction Form (Appendix 1).
We may charge a SGD$10 administrative fee for processing your access request. If we intend to charge you the fee for processing your access request, we will inform you via email or in writing.
Upon your request and subject to applicable laws, we shall correct any error or omission in your personal data and send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the correction, unless the other organisation does not need the corrected personal data for any legal or business purpose (or, with your consent, only to selected organisations).
If you wish to correct any error or omission in your personal data that is in our possession or under our control, please complete a Personal Data Access/Correction/Withdrawal Form (Appendix 1).
Upon your request and subject to applicable laws, we shall withdraw and delete your personal data and inform every other organisation to which the personal data was disclosed by us within a year before the request, unless the other organisation does not need the personal data for any legal or business purpose (or, with your consent, only to selected organisations).
If you wish to withdraw your personal data that is in our possession or under our control, please complete a Personal Data Access/Correction/Withdrawal Form (Appendix 1).
To express a concern, raise a question or make a complaint, please contact us at RSH (Singapore) Pte Ltd at 190 Macpherson Road, Level 7, Singapore 079914 or email@example.com in the first instance. We shall investigate and respond within 14 business days after we hear from you. Where this is not possible, a revised date shall be agreed with you.
Please note that this data privacy access and correction procedure is subject to change. Please review it periodically so that you will be aware of our privacy practices. If we make changes to our privacy notice, we will revise the “Last Updated” date at the bottom of this notice.
This form is to be used by individuals requesting access or to correct their own personal information, if any, that is in the possession or under our control of an RSH entity in Singapore (“RSH”).
As at June 2014, the RSH entities in Singapore include RSH Singapore Pte Ltd.
Data protection law is set out in the Personal Data Protection Act 2012 (“Act”) accessible from on the Singapore Statutes Online by the Attorney General’s Chambers, as well as associated regulations.
2. Your Rights
Under the Act you have (subject to certain exemptions) the right to access to your personal data held by RSH and to be provided with a copy of that information as well as the right to correct an error or omission in your personal data. RSH shall correct the personal data as soon as practicable and send the corrected data to other organisations to which the personal data was disclosed within a year before the correction is made, unless the other organisation does not need the corrected personal data for any legal or business purpose (or, with your consent, only to selected organisations).
3. RSH’s Rights
Where an exemption is available under the Act, RSH may not provide you with the information covered by the exemption. The main exemptions that may be applied include if the provision of the information could reasonably be expected to:
- – reveal personal data about another individual;
- – reveal the identity of the individual who has provided the personal data about you, and the individual has not consented to the disclosure of his or her identity; or
- – be contrary to national interest.
4. Payment For Access Request
RSH may charge you an administrative fee for each access request that you submit. If we intend to charge you a fee for processing your access request, we will provide you with a prior written estimate of the fee.
Applications that are subject to a fee will not be processed until the fee is paid in an acceptable form. All fee payments must be made by cheque. We do not accept credit cards, debit cards, cash, or any other currency.
Similarly, cheque payments that fail to clear will also result in the application not being processed. We will contact you in these situations.
Please submit the completed form in person, together with your proof of identity and fee (applicable) to:
RSH Singapore Pte Ltd
190 Macpherson Road, Level 7, Singapore 348548
Forms that are incomplete will be returned; forms that are complete but for which suitable identification and/or fee have not been received will be put on hold until you send us the missing items.
6. Processing by RSH
Applications shall be processed promptly, but in any event a response shall be made within 14 days, from the date that we accept the properly completed application form along with your proof of identity and fee. Where we are unable to respond to you within the said 14 days, we will notify you of the soonest possible time within which we can provide you with the information requested.
Application form will not be accepted or processed unless the application form is completed correctly with all requested information being supplied, signed, proof of identity provided and the correct fee paid.
For your protection, any correspondence that we send you (including any information that we send to you in response to your request) will be sent only to the residential address that you provided on this form.
Last revision: 30 June 2014