Personal Data Protection Act Notice
Ronald McDonald House Charities Singapore
UEN No.: S98SS0006C
Data Protection Notice (the “Notice”)
1. Policy Statement
At Ronald McDonald House Charities Singapore (“RMHC Singapore”), we respect the privacy and confidentiality of individuals’ personal data. We are committed to implementing policies, practices and processes to comply with the Singapore Personal Data Protection Act 2012 (“PDPA“) and other applicable laws.
This Data Protection Notice (“Notice”) sets out the basis which RMHC Singapore may collect, use, disclose or otherwise process personal data of persons in accordance with the applicable personal data protection laws and regulations. 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 otherwise process personal data for our purposes.
The PDPA sets out rules for governing the collection, use and disclosure of personal data by organisations. As defined in the PDPA, personal data refers to data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access.
Unless otherwise defined, terms used in this Notice shall have the meaning given to them in the PDPA.
2. Collection, Usage and Disclosure of Personal Data
Except where collection, use and/or disclosure of your personal data is permitted or required by the PDPA or other laws, we generally only collect, use and disclose your personal data if 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, use and/or disclosure of your personal data for those purposes.
We may also collect, use and/or disclose personal data without consent as permitted or required by the PDPA or other laws such as during the following situations:
· To respond to an emergency that threatens your life, health and safety or of another individual; and
· Necessary in the national interest, for any investigation or proceedings.
We will 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).
These personal data may be furnished to us in forms filled out by you, face to face meetings, email messages, or telephone conversations. We may also keep a record of any contact you have with us. These data would be collected only for business purposes or for the purpose(s) stated by us when we gather the personal data from you.
2.1 Types of Personal Data Collected
The types of personal data we may collect from you are generally as follows:
· Basic personal information: Name, gender, title, age or date of birth, organization, occupation or job responsibilities, phone number, mailing address, email address, contact details, details of family members (including contact details), education qualifications, volunteering experience and background, availability, language skills and other skills, and hobbies and interests;
· Special categories of personal information: religious or other beliefs, racial or ethnic origin, sexual orientation, marital status, biometric data, audio-visual information and health or medical history;
· Registration data: newsletter or mailing list requests, event or seminar registrations, dietary preferences, subscriptions, downloads, and usernames/passwords;
· 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;
· Marketing data: data (including photographs and video recordings) about our beneficiaries, and individual participation in volunteer drives, donation drives, our activities and events, credentials, associations, volunteer interests and preferences;
· 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; and
· Device data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data)
2.2 Purpose of Collecting Personal Data
We may collect and use the personal data we have collected for the following purposes:
· To recruit volunteers and donors, and to consider individuals for employment and contractor opportunities, and manage on-boarding procedures (for both employees and volunteers);
· To conduct background checks and due diligence on job candidates, employees, contractors, volunteers and donors, as well as on organisations which we partner with, and to address compliance and legal obligations;
· To manage and administer employment relationships and employee benefits;
· To manage our operations and administer our relationships with volunteers, donors, beneficiaries and users of our programs, and business partners;
· To organise and implement charitable and fundraising activities, events and programs, including assessing whether a potential beneficiary is suitable for receiving assistance from us;
· To make our websites more intuitive and easy to use, and to protect the security and effective functioning of our websites and information technology systems;
· To provide marketing services, such as providing volunteers, donors, partners (or other persons who have provided us with their personal data) and the general public with information about events or services that may be of interest to them, including information about our charitable activities, events and programs, and groups of specific interest (e.g., specific types of beneficiaries); and
· To respond to, handle and/or process queries, requests, applications, complaints, and feedback;
· To comply with internal reporting, any applicable laws, regulations, codes of practice, guidelines, rules or compliance procedures, or to assist in law enforcement, investigations and/or requests from governmental agencies or regulators, court orders or other legal process, and to defend against legal claims
You have the right of choice regarding the collection, usage and/or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be able to perform our obligations as stated in this notice. You have the right to object to the processing of your personal data and withdraw your consent in the manner described below.
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 personal data collection form submitted to us (if any). Depending on the complexity of the request and its impact to our relationship with you, we will not collect or, within 30 days of our receipt of your request, cease using and/or disclosing your personal data in accordance with your request.
The purposes listed above 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).
In the case where we receive unsolicited personal data via email or any other communication channels, the unsolicited personal data will not be retained and will be securely disposed of immediately.
2.3 Disclosure of Personal Data
We may disclose some of the personal data we have collected to any or all of the following organisations outside of RMHC Singapore, for the purposes stated above:
· Ronald McDonald House Charities, Global;
· our business partners (e.g., hospitals where we conduct charitable activities, events or programs);
· suppliers and service providers (e.g., financial institutions, payroll service providers, infrastructure and IT services providers, third-party legal and financial consultants, providers of external venues where we host activities or events);
· volunteers or donors; and
· government agencies, regulators or other government-affiliated organisations.
We may disclose your personal data (a) with your consent, 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; (b) to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your personal data); or (c) with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in paragraph 2.2 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
3. Withdrawal of Consent; Access and Correction of your Personal Data
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. 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 using the form provided below, or by clicking on the “unsubscribe” button in any online or email service provided by us.
If you wish to obtain access or make corrections to the personal data that has been collected by us, you may also do so by submitting a duly completed copy of the form provided below.
We will respond to any requests from you as soon as reasonably possible but will require a reasonable amount of time to process your request.
If you are withdrawing your consent, we will notify you of the consequences of such withdrawal including any legal consequences which may affect your rights and obligations to us. Depending on the scope and nature of your request, we may not be in a position to continue providing our services to you upon your withdrawal of consent and we will, in such circumstances, notify you before processing your request. You can choose to cancel your withdrawal of consent by informing our Data Protection Officer in writing or by email. In general, we shall seek to process your request within ten (10) business days of receiving it. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect.
If you are submitting any access or correction requests, please note that a reasonable administration fee may be charged in connection with an access request. If any such fee is applicable, we will notify you before processing your request, we may need to verify your identity by checking identification document, and the legitimacy of your request. If we are unable to process your access or correction request, we will generally inform you of the reasons for not being able to do so (except where we are not required to provide such reasons under the PDPA).
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 your request relates to personal data which we are processing on behalf of another organisation, we will instead forward your request to the relevant organisation for their necessary action.
Finally, please note that your withdrawal of consent does not affect our right to continue collecting, using and/or disclosing your personal data where collection, use or disclosure without consent is permitted or required under the PDPA or other applicable laws.
4. Accuracy of Personal Data
We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
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.
5. Protection of Personal Data
We have implemented appropriate security precautions to protect your personal data that is in our possession or under our control to prevent unauthorised access, use, disclosure, or similar risks. These include administrative, physical and technical measures such as antivirus protection software, encryption and the use of privacy filters to secure all storage and transmission of personal data by us and policies which restrict the disclosure of personal data both internally and externally only on a need-to-know basis.
If there is a need to disclose your Personal Data to third parties in line with the purposes mentioned in paragraph 2.3, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.
Please, however, be aware 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.
6. Retention of Personal Data
We will cease to retain your personal data or remove the means by which the data can be associated with you in a secure manner, as soon as it is reasonable to assume that such data is no longer needed for any business or legal purposes in RMHC Singapore.
7. Transfer of Personal Data
Unless for business-related needs, 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 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.
8. Data Breach Notification
In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate, report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required. If we are a Data Intermediary, we shall inform the Data Controller immediately of any data breach so they can promptly assess the impact and comply with their data breach notification obligation.
9. Data Protection Officer
Should you have any feedback or enquiries relating to this Notice, or if you wish to make any complaint or request in respect of your personal data, please contact our Data Protection Officer at:
Ronald McDonald House Charities Singapore, 5 Lower Kent Ridge Road, National University Hospital, Main Building Level 4, Singapore 119074.
Telephone No.: +65 6778 1934
Email: [email protected]
10. Effect of Notice; Review and Revision
This Notice applies in conjunction with any other notices, contractual clauses and consent forms that apply in relation to the collection, use and disclosure of your personal data by us.
This Notice may be revised 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
This Notice is prepared pursuant to the PDPA and governed by the laws of Singapore.
First Updated on: August 28th, 2020
Last Updated: August 22nd, 2022