Data Protection Notice for Volunteers, Board Members and Donors
DATA PROTECTION NOTICE FOR VOLUNTEERS, BOARD MEMBERS AND DONORS
This Data Protection Notice (“Notice”) sets out the basis which Ronald McDonald House Charities Singapore (“RMHC Singapore”, “we, “us” or “our”) may collect, use, disclose or otherwise process personal data of our volunteers, board members and donors in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“personal data” means data, whether true or not, about an individual (whether a donor, board member, volunteer or otherwise) 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.
2. The types of personal data we may collect from you are generally as follows:
a. Basic personal information: Name, organization, occupation or job responsibilities, phone number, mailing address, email address, contact details, education qualifications, volunteering experience and background, availability, language skills and other skills, and hobbies and interests;
b. Special categories of personal information: religious or other beliefs, racial or ethnic origin, marital status, biometric data, audio-visual information and health or medical history;
c. Registration data: newsletter or mailing list requests, event or seminar registrations, dietary preferences, subscriptions, downloads, and usernames/passwords;
d. Customer service data: personal data received from partners or donors in respect of employees, volunteers, or other individuals affiliated with RMHC Singapore known to our partners, invoicing details and payment history, and other feedback from our partners or donors;
e. Marketing data: data (including photographs and video recordings) about individual participation in volunteer drives, donation drives, our activities and events, credentials, associations, volunteer interests and preferences; and
f. Compliance data: government identifiers (such as the NRIC No., FIN and passport numbers), copies of identification documents (such as the NRIC, work pass or passport), and data collected for completing anti-money laundering compliance procedures and related donor due diligence.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. 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).
5. We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
a. To respond to an emergency that threatens your life, health and safety or of another individual; and
b. Necessary in the national interest, for any investigation or proceedings.
6. We may collect and use your personal data for any or all of the following purposes:
a. establishing or managing your relationship with us. This includes:
i. Where you are a volunteer,
· processing and evaluating your suitability to volunteer; and
· monitoring, evaluating and/or auditing of services you participated in.
ii. where you are a donor,
· processing your donations.
iii. Where you are a board member,
· processing and evaluating your suitability to a board member
· monitoring, evaluating and/or auditing of services you participated in
b. providing you with information on our upcoming events or activities, where you have specifically requested to receive such information;
c. verifying your identity and the accuracy of your personal details and other information provided;
d. responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
e. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any government and/or regulatory authority; and
f. transmitting to any unaffiliated third parties, including our third-party service providers and agents, and relevant government and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
7. If you choose not to provide us with your personal data for the purposes listed above, you may submit a request in writing or via email to our Data Protection Officer at the contact details provided below or indicate in the relevant portion of this form. Whilst we respect your decision, please note that depending on the nature and extent of your request, we may not be in a position to continue our relationship with you (as the case may be). We shall, in such circumstances, notify you before continuing to process your request. 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 carry out your request, 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).
8. We may disclose your personal data:
a. with your consent, where such disclosure is required for, or in connection with, the provision of the services requested by you;
b. with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 5 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential; or
c. 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
d. any other party to whom you authorised us to disclose your personal data to, or where necessary, to undertake any action requested by you.
9. 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).
WITHDRAWING YOUR CONSENT
10. 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 below, or by clicking on the “unsubscribe” button in any online or email service provided by us. 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.
11. 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 10 business days of receiving it.
12. 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 in a position to continue tour 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.
13. Please note that withdrawing 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
14. 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 via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
15. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request.
16. 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.
17. We will respond to your request as soon as reasonably possible. In general, our response will be 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
18. 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 up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
19. When we disclose your personal data to third parties in line with the purposes mentioned in paragraph 8, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your personal data.
20. 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. In the event of a personal data breach, we will endeavour to notify the affected parties no later than within 3 calendar days from when we become aware of the breach.
ACCURACY OF PERSONAL DATA
21. 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.
22. We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
RETENTION OF PERSONAL DATA
23. 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.
24. 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.
25. We dispose of or destroy such documents containing your personal data in a secure manner when the retention limit is reached and it is reasonable to assume that the permitted purpose is no longer being served by their retention.
26. For Donors, records will be kept for 1 year after the last donation. For Board Members, records will be kept for 1 year after end of term. For Volunteers, records will be kept for 5 years after last volunteering session. Records will be disposed of in a secure manner immediately after the said retention period.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
27. 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, including entering into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.
DATA PROTECTION OFFICER
28. 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 complaint or request, in the following manner:
Telephone No. +65 6778 1934
Email [email protected]
Address 5 Lower Kent Ridge Road, National University Hospital, Main Building Level 4, Singapore 119074
EFFECT OF NOTICE AND CHANGES TO NOTICE
29. 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.
30. 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 relationship with us constitutes your acknowledgement and acceptance of such changes.
Effective date: 1/11/2019
Second update: 2/12/2021
3rd update: 22/8/2022
4th update: 27/3/2023