Privacy Policy
At Old Victorians’ Association, we are committed to protecting and safeguarding the personal data that we have collected from you.
Personal data in Singapore is protected under the Personal Data Protection Act 2012 (“PDPA”). Personal data refers to 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 (“Personal Data”). Personal Data includes, but is not limited, to the following:
(i) Name
(ii) NRIC / FIN number/ Passport number
(iii) Photograph or video image of an individual
(iv) Mobile number
(v) Personal email address
(vi) Thumbprint
(vii) DNA profile
(viii) Name and residential address
(ix) Name and residential telephone number.
This Personal Data Protection Policy (“Policy”) describes the types of Personal Data we collect through our operations. The Policy also sets forth how we use this data, provides other details about our personal data practices, and explains how to contact us if you have any questions or concerns.
The data protections provisions of the PDPA (Parts III to VI of the PDPA) (“Data Protection”) came into effect on 2 July 2014. Under the PDPA, organisations can continue to use Personal Data that they have collected before the Data Protection provisions came into effect on 2 July 2014 for the purposes for which it was collected unless consent for the collection has been withdrawn by the individual concerned. If an organisation intends to use a Personal Data which it has collected for a different purpose for which that Personal Data was collected, the organisation would need to obtain fresh consent from the individual for the use of his or her Personal Data.
Accordingly, after 2 July 2014, the Old Victorians’ Association is required to notify and obtain consent from an individual for the collection, use and disclosure of the individual’s Personal Data which shall be governed by this Policy.
1. Our Obligations
2. Collection of Personal Data
3. Purpose of Collection
4. Consent and Right to Withdraw Consent
5. Rights of Access
6. Disclosure of Personal Data
7. Security, Storage and Duration of Data Retention
8. Exceptions and Exclusion of Liability
9. Integrity of Personal Data
10. Transferring and Sharing of Personal Data
11. Protection of Personal Data in Old Victorians’ Association Possession
12. Language
13. Changes to our Personal Data Protection Policy
14. Governing Law
1. Our Obligations:
Consent Obligation
Old Victorians’ Association only collects, uses or discloses Personal Data of which you have given your consent.
Old Victorians’ Association allows you to withdraw consent, with reasonable notice, and shall inform you of the likely consequences of withdrawal. Upon withdrawal of consent to the collection, use or disclosure for any purpose, Old Victorians’ Association shall cease such collection, use or disclosure of your Personal Data.
Purpose Limitation Obligation
Old Victorians’ Association may collect, use or disclose your Personal Data for the purposes that a reasonable person would consider appropriate in the circumstances and for which you have given consent.
Old Victorians’ Association may not, as a condition of providing a service, require you to consent to the collection, use or disclosure of your Personal Data beyond what is reasonable to provide that service.
Notification Obligation
Old Victorians’ Association shall notify you of the purposes for which Old Victorians’ Association is intending to collect, use or disclose your Personal Data on or before such collection, use or disclosure of Personal Data.
Access and Correction Obligation
Upon request, your Personal Data and information about the ways in which your Personal Data has been or may have been used or disclosed within a year before the request should be provided. However, Old Victorians’ Association is prohibited from providing you access if the provision of the Personal Data or other information could reasonably be expected to:
- cause immediate or grave harm to your safety or physical or mental health
- threaten the safety or physical or mental health of another individual
- reveal Personal Data about another individual
- reveal the identity of another individual who has provided the Personal Data, and the individual has not consented to the disclosure of your identity or
- be contrary to national interest.
Old Victorians’ Association shall correct any error or omission in your Personal Data upon your request. Unless Old Victorians’ Association is satisfied on reasonable grounds that the correction should not be made, Old Victorians’ Association should 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, or with your consent, only to selected organisations.
Accuracy Obligation
Old Victorians’ Association shall make reasonable effort to ensure that Personal Data collected by or on behalf of Old Victorians’ Association is accurate and complete if it is likely to be used to make a decision that affects you, or if it is likely to be disclosed to another organisation.
Protection Obligation
Old Victorians’ Association shall make reasonable security arrangements to protect the Personal Data that Old Victorians’ Association possesses or controls to prevent unauthorised access, collection, use, disclosure or similar risks.
Retention Limitation Obligation
Old Victorians’ Association shall cease retention of Personal Data or remove the means by which the Personal Data can be associated with particular individuals when it is no longer necessary for any business or legal purposes.
Transfer Limitation Obligation
Old Victorians’ Association shall transfer Personal Data to another country only according to the requirements prescribed under the regulations, to ensure that the standard of protection provided to the Personal Data so transferred will be comparable to the protection under the PDPA, unless exempted by the Personal Data Protection Commission.
Openness Obligation
Old Victorians’ Association shall make information about Old Victorians’ Association’s data protection policies, practices and complaints process available on request.
2. Collection of Personal Data
The types of Personal Data that we collect essentially depend on the purpose for collecting them. Thus, depending on the purpose of the collection of the Personal Data, the Personal Data collected may include the following:
(a) Name
(b) Date of Birth
(c) Gender
(d) NRIC / Passport / Birth Certificate
(e) Contact Information and Address
(f) Nationality / Race
(g) Photograph
(h) Education
(i) Occupation / Designation
(j) Income
(k) Involvement in other Civic Institutions
(l) Feedback / Performance Review
(m) Employment Records
(n) Family Records
(o) References
(p) Banking Particulars, Credit Card Details
(q) Information on tax and CPF
(r) Sensitive Information such as criminal record, religion, health and etc.
(s) Such other information as may be required for specific reasons.
3. Purpose of Collection
The Personal Data as provided/furnished by you to Old Victorians’ Association or collected by Old Victorians’ Association from you or through such other sources as maybe necessary for the fulfilment of the purposes at the time it was sought or collected, will be used for such purpose and or for the following reasons (collectively, the “Purposes”):
- Assessing interest in programmes/services.
- Assessing application for programmes/services.
- Assessing application for employment.
- Communicating with its students/parents/guardians of its students.
- Providing services to process billing / payment transactions.
- Responding to an individual’s inquiries.
- Administering participation in any programme/event/activity organised by Old Victorians’ Association.
- For marketing and promotional activities, market surveys, trend and statistical analysis.
- For finance activities.
- For credit assessments, financial and background investigation as and when deemed necessary.
- For the maintenance and upkeep of internal records, filing and operations.
- For meeting any legal or regulatory requirements relating to our provision of services and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or our affiliates.
- To enter into the necessary agreement and/or contract.
- For handling the report for lost item, customer complaints and taking appropriate action relating thereto.
- For security and crime prevention purposes, risks management, safeguarding Old Victorians’ Association in the event of any claim, litigation, suits and etc.
- For any other grounds or reasons (the Personal Data collected will correspond to such grounds or reasons).
Please note that it is necessary for an individual to provide us with your accurate Personal Data. Failure to do so may result in us being unable to process and/or use your Personal Data in relation to the Purposes.
4. Consent and Right to Withdraw Consent
You shall be invited to give your consent to Old Victorians’ Association to collect, use and/or disclose your Personal Data for the purposes of programmes/classes/services soliciting, research activities and future event notification and publicity as well as Old Victorians’ Association’s news dissemination.
By indicating your acceptance of the terms of this Policy, you shall have expressly consented to the processing of your Personal Data by Old Victorians’ Association or any of our authorised staff, partners and/or contractors for the Purposes outlined in paragraph 3 above.
Notwithstanding anything to the contrary, you may at any time withdraw your consent to Old Victorians’ Association processing any Personal Data of yours or to any part or portion of the processing by sending to Old Victorians’ Association at the address set out below a written notice of withdrawal and within the period prescribed under the Act. Old Victorians’ Association shall take all necessary measures to give effect to your withdrawal of consent, to the extent that such withdrawal does not conflict with any of Old Victorians’ Association’s other legal obligations.
5. Rights of Access
You may at any time hereafter make written inquiries, complaints and request for access to, or correction of, your Personal Data or limit the processing of your Personal Data by submitting such written request to the Data Protection officer of the Old Victorians’ Association via e-mail to vp2@ova.org.sg or post it to the address as set out below:
Data Protection Officer
Old Victorians’ Association
c/o Victoria School
2 Siglap Link
Singapore 448880
Data Protection Officer : Loke Swee Leong
Any Personal Data retained by us shall be destroyed and/or deleted from our records and system in accordance with our retention policy in the event such data is no longer required for the said Purposes.
6. Disclosure of Personal Data
The Personal Data provided to us shall be kept confidential, however, we may disclose your Personal Data to the following parties:
- Our business partners that provide related services in connection with our services
- Our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our services
- Our third party service providers, third party management companies, sub-contractors or other parties as may be deemed necessary by us to facilitate your dealings with us
- Our appointed service providers in fulfilling our services and
- Any persons, government agencies, statutory authorities and/or industry regulators, whom we are compelled or required to do so pursuant to any law
Third parties are legally tasked with processing your Personal Data in line with principles specified by Old Victorians’ Association and may not use it for any other purposes. Third parties are also held responsible for securing your Personal Data at an appropriate level of security in relation to applicable data protection laws and widely accepted industry standards.
Old Victorians’ Association reserves its right to use or disclose any data as needed to satisfy any law, regulation or legal request, to protect the integrity of the Online Service, to fulfill your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
7. Security, Storage and Duration of Data Retention
Old Victorians’ Association is committed to ensuring that your Personal Data is secure, and in connection therewith, suitable processes and procedures have been put in place to ensure that all Personal Data collected by us shall be stored and/or filed in such manner as to ensure that the Personal Data maintains its accuracy, integrity, remains confidential, is protected against loss, misuse, modification and unauthorised or accidental access, disclosure, alteration, destruction or manipulation.
Old Victorians’ Association shall store and/or retain all Personal Data only for as long as required for the fulfilment of the Purposes stated in paragraph 3 above or pursuant to any legal obligation imposed upon Old Victorians’ Association or by virtue of any applicable law that may from time to time be in force.
8. Exceptions and Exclusion of Liability
Notwithstanding the foregoing provisions, Old Victorians’ Association reserves the right to refuse to entertain any request for withdrawal of consent, access or correction in the following circumstances:
- Where there is an insufficiency of information provided by any party making a request to enable Old Victorians’ Association to positively locate or identify the Personal Data in question;
- Where there is reasonable doubt surrounding the identity of the person making the request or where Old Victorians’ Association feels that the requesting party is not in fact the owner or the subject of the Personal Data in question and is not lawfully entitled to make any requests in relation to the Personal Data;
- Where permitting access or correction would be tantamount to a violation of an order of Court
- In requests for access or for correction (excluding instances of withdrawal of consent):
- where the burden or expense of entertaining the request for access or correction is disproportionate to the risk to the privacy of the party making a request
- where compliance with the request would involve the unauthorised disclosure of Personal Data belonging to a third party
- where compliance would result in the disclosure of confidential commercial information or
- where access is regulated by another law
In the area of Personal Data protection, Old Victorians’ Association shall not be liable for any purported violation, breach or non-compliance with any precepts of privacy or the protection of Personal Data in the following instances:
- Where an act of nature or event outside the control of Old Victorians’ Association results in the damage or malfunction or destruction in any equipment or machinery used to secure, store or process Personal Data
- Where Personal Data is readily available or able to be found in the public domain and
- Where despite Old Victorians’ Association’s best efforts, there is unauthorised access, modification, alteration, misuse, tampering or abuse of Personal Data caused by the malicious or fraudulent or criminal acts or conduct of a third party not being under the control or direction of Old Victorians’ Association.
9. Integrity of Personal Data
You are responsible for ensuring that the Personal Data you provide to us is accurate, complete and not misleading and that such Personal Data is kept up to date. We may request your assistance to procure the consent of third parties whose Personal Data is provided by you to us and you agree to use your best endeavours to do so.
10. Transferring and Sharing of Personal Data
It may be necessary, if so required for any of the Purposes to transfer your Personal data outside of Singapore or to disclose your Personal Data to the Old Victorians’ Association Family (as defined below), our business partners, associates, service providers and/or relevant authorities, who may be located within or outside Singapore. Save for the foregoing, your Personal Data will not be knowingly transferred to any place outside Singapore or be knowingly disclosed to any third party.
Old Victorians’ Association also does not sell, transfer or disclose personal information to third parties outside the Old Victorians’ Association family which comprises the Old Victorians’ Association, its [subsidiaries/affiliates] (collectively, the “Old Victorians’ Association Family”) and our service vendors. However, with your permission, we will, on occasion send marketing information on behalf of our business partners or associates about products or services they provide that may be of interest to you. You may be asked if you wish to receive marketing materials from Old Victorians’ Association’s partners or associates. If you elect to receive such materials, Old Victorians’ Association will not share your personal information with such partners or associates but rather it will send an e-mail on behalf of the partners or associates.
11. Protection of Personal Data in Old Victorians’ Association’s Possession
Old Victorians’ Association shall limit the collection and use of personal information to what is necessary to administer its services and to deliver superior service to you. To serve you better, Old Victorians’ Association may combine the information which you have given to us through our website or other channels.
Old Victorians’ Association shall protect the confidentiality of all personal information which you have shared with us. In cases where we share personal information with the Old Victorians’ Association Family, or partners, we will protect that personal information with a strict confidentiality as stated in our agreement. Companies hired by us to provide support services or to act as our agent must conform to our privacy standards.
Old Victorians’ Association corporate policies stipulate that any staff with access to confidential customer information is not permitted to use or disclose such information except for business purposes. All staff are required to safeguard such information as specified in their confidentiality agreements with Old Victorians’ Association.
In all cases, your personal information is strictly protected by a confidentiality agreement. We do not allow any non-affiliated company to retain your personal information any longer than it is necessary to provide you with the service or information unless you have granted us permission to do so.
Staff of Old Victorians’ Association shall sign the confidentiality agreement to undertake not to misuse or disclose Personal Data in their possession during their cause of work and to take every precaution to ensure all Personal Data under their possession are being kept confidential at all times.
12. Language
This Policy is issued in English language.
13. Changes to the Personal Data Protection Policy
This Policy is effective as of July 1, 2014. From time to time, it may be necessary for Old Victorians’ Association to change this policy. If we change our policy, we will post the revised version on our corporate website, so we suggest that you refer to the Policy online which may be updated from time to time.
14. Governing Law
This Data Protection Policy shall be governed in all respects by the laws of Singapore.
