Personal Data Protection Policy
Anglo-Chinese
School (Barker Road) recognises the importance of personal data entrusted to us.
We strongly
believe and are committed to discharging our duty to ensure that your personal
data is properly managed, protected and processed.
This Data Protection Policy is intended to assist you in understanding how we collect, use, disclose, protect and process any personal data that we receive from you, and designed in accordance with the requirements under the Personal Data Protection Act 2012 (“PDPA”).
1.
Introduction to the Personal Data
Protection Act 2012
1.1
“Personal
Data” is hereinafter defined as data, whether true or not, about an individual
who can be identified from that data or from that data and other information to
which the organisation has or is likely to have access.
1.2
Various
examples of Personal Data may include full names, NRIC/FIN numbers, passport
numbers, mobile telephone numbers, photographs or video images of an individual,
and personal email.
1.3 In general, before we collect any personal data from you, we will notify you of the purposes for which your Personal Data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your Personal Data for the intended purposes.
2. Purposes for
Personal Data
2.1 Depending
on the type of relationship you have with us (e.g. student, parent, alumnus,
staff, applicant, vendor, service provider), the Personal Data that we gather
from you may be collected, used and/or disclosed for the following purposes.
2.1.1 Evaluating suitability for admission or employment, enrolling
or employing, providing educational courses and training, including sending
materials on course/study/assignment/lecture materials, information on time
tables and examination details via postal mail, electronic mail, SMS or MMS,
fax and/or voice calls;
2.1.2
Administering and/or managing relationships with
Anglo-Chinese School (Barker Road) (including
responding to enquiries, the mailing of correspondence, statements or notices
which could involve the disclosure of certain Personal Data to bring about
delivery of the same);
2.1.3
Carrying out due diligence or other screening
activities (including background checks) in accordance with legal or regulatory
obligations or risk management procedures that may be required by law or put in
place by Anglo-Chinese School (Barker Road),
including the obtaining of references and/or other information from prior
educational institutions and employers;
2.1.4
Processing application(s) for scholarships
and/or financial aid, and research support, and administering and managing
scholarship/financial aid/grant and other support programmes, which may include
use of Personal Data for development and fund raising activities and disclosure
of Personal Data to donors, grantors, external evaluators and/or external
organisations for purposes of periodic reports, event invitations, surveys
and/or publicity of Anglo-Chinese School (Barker
Road)’s related programmes;
2.1.5
Investigating possible fraud, misconduct,
unlawful action or omission, and utilizing electronic access and video systems
to maintain campus security of persons or property, control access and
investigate suspicious or inappropriate activities;
2.1.6
Responding to requests for information from
government or public agencies, ministries, statutory boards or other similar
authorities or non-government agencies authorised to carry out specific Government
services or duties;
2.1.7
Carrying out market-related, evaluative or similar
research and analysis for Anglo-Chinese School
(Barker Road)’s operational strategy and policy planning purposes,
including providing data to external parties for university programme
evaluation and to students’ former academic institutions and to partner
institutions for jointly administered programmes;
2.1.8
Outreach and engagement to garner support and
resources for Anglo-Chinese School (Barker Road),
its community and affiliated institutions;
2.1.9
Supporting Anglo-Chinese
School (Barker Road) functions including, but not restricted to, the
teaching and personal and professional development of students, research and
administration of Anglo-Chinese School (Barker
Road);
2.1.10
Processing and administering applications for
overseas exchange programmes, summer school, overseas internships and other
overseas activities and administering such programmes including disclosure of
information to overseas universities, employing and training organisations;
2.1.11
Processing, administering and conferring awards
of prizes, medals, scholarships, classes of honours and other marks of
distinction, and student or graduation status, and publication or releasing of
information on the same;
2.1.12
Engaging alumni including but not limited to
notification on Anglo-Chinese School (Barker
Road) and alumni-related initiatives and activities, invitation to Anglo-Chinese School (Barker Road) and
alumni-related events, updating of alumni information, invitation to
participate in alumni surveys and sending of communication collaterals;
2.1.13
Processing applications and enrolment activities
related to health, life and travel insurance and service provision as well as
concession cards, and campus accommodation and administering matters related to
use of these services;
2.1.14
Processing applications for and administering
local and overseas career related activities, events, programmes, internships,
employment opportunities, and career coaching, and sharing information with
companies (whether local or overseas) for purposes of recruitment, internship,
industrial attachment, job placement and research support;
2.1.15
Facilitating participation in student life and
alumni development opportunities which may include social, cultural, athletic,
and educational activities, events, volunteering and training programmes,
student membership and leadership positions in clubs, societies, halls and
residences, and orientation/reception activities;
2.1.16
Taking of photographs and/or videos (whether by Anglo-Chinese School (Barker Road) staff or
third party photographers and/or videographers) during school programmes, events
or seminars organised by Anglo-Chinese School
(Barker Road) or its affiliates for publicity purposes;
2.1.17
For record keeping (including and not limited to
campus video surveillance, visitor registration);
2.1.18
To provide updates on Anglo-Chinese School (Barker Road) events;
2.1.19
If consented to in the registration form and/or
other methods of consent notification, providing marketing, advertising and
promotional information via postal mail, electronic mail, SMS or MMS, fax
and/or voice calls;
2.1.20
Any other purposes which Anglo-Chinese School (Barker Road) may inform
you of in writing from time to time, but for which Anglo-Chinese School (Barker Road) will seek
your separate consent.
2.2 In
order to conduct our operations more smoothly, 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, which may be sited locally or
outside of Singapore, for one or more of the above-stated Purposes. This is
because such third party service providers, agents and/or affiliates or related
corporations would be processing your Personal Data on our behalf 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 any of your
Personal Data to any third parties without first obtaining your express 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:
3.2.1 Situations in which the
disclosure is required based on the applicable laws and/or regulations;
3.2.2
Situations in which the purpose of such
disclosure is clearly in your interests and consent cannot be obtained in a
timely way;
3.2.3
Situations
in which the disclosure is necessary to respond to an emergency that
threatens the life, health or safety of yourself or another individual;
3.2.4
There are reasonable grounds to believe that the
health or safety of yourself or another individual will be seriously affected
and consent for the disclosure of the data cannot be obtained in a timely way,
provided that we shall, as soon as may be practicable, notify you of the
disclosure and the purposes of the disclosure;
3.2.5
Situations
in which the disclosure is necessary for any investigation or
proceedings;
3.2.6
Situations 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;
and/or
3.2.7
Situations in which the disclosure is to a
public agency and such disclosure is necessary in the public interest.
3.3 Where Personal Data is disclosed to third parties with your express
consent, we will provide for adequate forms of protection over such Personal
Data and employ our best efforts to require such third parties to protect your
Personal Data in compliance with the PDPA and our data protection policies.
4
Request for Access, Correction and/or
Withdrawal of Personal Data
4.1 You may request to access and/or correct the Personal Data
currently in our possession, or have the option to withdraw your consent for
the collection, use and/or disclosure of your Personal Data in our possession
or under our control at any time by submitting a written request to our PDPA
Contact Person (See Below).
4.2 For a request to access your Personal Data, we will
provide you with the relevant Personal Data within a reasonable time from such
a request being made.
4.3 For a request to correct your Personal Data, once we
have sufficient information from you to deal with the request, we will send the corrected Personal Data to every
other organisation to which the Personal Data was disclosed by us within a year
before the date the correction was made, unless that other organisation does
not need the corrected personal data for any legal or business purpose.
4.4 For a request to withdraw consent, 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.
4.5 The withdrawal of your consent could result in certain
legal consequences arising from such withdrawal. In this regard, depending on
the extent of your withdrawal of consent for us to process your Personal Data,
it may mean that we will be unable to continue with your existing relationship
with us.
4.6 We may also be charging you a reasonable fee for the handling
and processing of your request to access and/or correct your Personal Data. You
will be notified in advance of such cost, and we will provide you with a
written estimate of the fee we will be charging.
5.
Administration and Management of Personal Data
5.1 We will take reasonable efforts to ensure that your Personal
Data is accurate and complete and updated.
5.2 Reasonable security arrangements will be made to ensure
that your Personal Data is adequately protected and secured. Appropriate
security arrangements will be taken to prevent any unauthorized access,
collection, use, disclosure, copying, modification, leakage, loss, damage and/or
alteration of your Personal Data. However, we cannot assume responsibility for
any unauthorized use of your Personal Data by third parties which are wholly
attributable to factors beyond our control.
5.3 We will also take reasonable efforts and measures to
ensure that the 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.
Updates on Data Protection Policy
6.1 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.
6.2 We reserve the right
to amend the terms of this Data Protection Policy at our absolute discretion.
You may request for the latest version of the Data Protection Policy at any
time.
6.3 You are strongly
encouraged to check and/or request for the latest version of the Data
Protection Policy from time to time on our website, https://acsbr.moe.edu.sg, to
ensure that you are well informed of our latest policies in relation to
Personal Data Protection.
7.
Complaint
Process and Feedback
7.1 If
you have any complaint, grievance or feedback regarding how we are handling
your Personal Data or about our compliance with the PDPA, you are welcome to contact
us with your complaint, grievance or feedback.
7.2 Kindly
contact us through one of the following methods with your complaint, grievance
or feedback:
7.2.1
Singapore
Telephone Number: 62561633
7.2.2
Email: acsbr@moe.edu.sg Attention it to
the ‘Data Protection Officer’
7.2.3 Office
Address: Anglo-Chinese School (Barker Road), 60 Barker Road, Singapore 309919
7.3 We
will certainly aim to deal with any complaint, grievance or feedback that you
may have efficiently and fairly.