This Data Protection Notice (“Notice”) sets out the basis which Koh Kock Leong Enterprise Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). This policy 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.
COLLECTION, USE AND DISCLOSURE OF DATA
1. 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, (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws, or (c) CCTV images of you are recorded for the purpose of crime prevention and personal safety. 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).
2. If we do request to collect and use your data, it may be for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity and security;
(c) employment and job application;
(d) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(e) managing your relationship with us;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) any other incidental business purposes related to or in connection with the above.
3. We may disclose your data:
(a) 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; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of our provision of the goods or services requested by you.
4. The purposes listed in the above clauses 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).
5. We may collect, use and disclose individual personal data pursuant to an exception under the PDPA law such as assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.
WITHDRAWING CONSENT
6. Individuals have choices regarding our collection, use 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 in this section.
7. 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 in writing via email. You may withdraw consent and request us to stop collecting and/or using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email to our Data Protection Officer.
8. Upon receipt of your 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 and effect your request within 10 working days after receiving the request.
9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your request. 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 writing via email.
10. 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
11. 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, you may submit your request in writing via email to our Data Protection Officer.
12. 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.
13. We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within 30 days after receiving your access request, we will inform you in writing via email within 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 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).
14. We will respond to your correction request as soon as reasonably possible. Should we not be able to correct the correction request within 30 days after receiving your request, we will inform you in writing via email on the time by which we will be able to correct your correction request. If we are unable 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).
15. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
16. We will not provide information under the access requirement for: –
(a) opinion data kept solely for an evaluative purpose;
(b) any examination, examination scripts and, prior to the release of examination results, examination results;
(c) the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;
(d) personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre;
(e) documents related to a prosecution if all proceedings related to the prosecution have not been completed;
(f) personal Data subject to legal privilege;
(g) personal Data which, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organisation;
(h) personal Data collected, used or disclosed without consent pursuant to the exemptions in the PDPA, for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed;
(i) the personal data was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he was appointed to act —
>> under a collective agreement under the Industrial Relations Act (Cap. 136) or by agreement between the parties to the mediation or arbitration;
>> under any written law; or
>> by a court, arbitral institution or mediation centre.
(j) any request: –
>> That would unreasonably interfere with the operations of the organisation because of the repetitious or systematic nature of the requests;
>> If the burden or expense of providing access would be unreasonable to the organisation or disproportionate to the individual’s interests;
>> For information that does not exist or cannot be found;
>> For information that is trivial; and
>> That is otherwise frivolous or vexatious.
(k) personal Data or other information shall not be provided to an individual if the provision of that Personal Data or information could reasonably be expected to:
>> Threaten the safety or physical or mental health of an individual other than the individual who made the request;
>> Cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
>> Reveal Personal Data about another individual;
>> Reveal the identity of an individual who has provided Personal Data about another individual and the individual providing the Personal Data does not consent to the disclosure of his/her identity; or be contrary to national interest.
(l) If Personal Data has been disclosed to a prescribed law enforcement agency without the consent of the individual or pursuant to the exemptions in the PDPA, we shall not be required to inform the individual of such disclosure.
17. Correction request will not be approved in respect of:
(a) opinion data kept solely for an evaluative purpose;
(b) examinations conducted by educational institutions, including examination scripts and, prior to the release of examination results;
(c) personal data of beneficiaries of a private trust used exclusively for trust administration;
(d) personal data held by arbitral institutions or mediation centers solely for arbitration or mediation proceedings; or
(e) documents related to a prosecution if all proceedings have not concluded.
PROTECTION OF DATA
18. To safeguard your 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 and firewall protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
19. 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.
ACCURACY OF DATA
20. We generally rely on the 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 via email.
RETENTION OF PERSONAL DATA
21. We may retain your data for a period of time where your data is used to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
22. 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
23. 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.
NOTIFICATION OF BREACH
24. The Contractor (The contractor who require Koh Kock Leong Enterprise Pte Ltd to disclose personal data for security clearance purpose) shall immediately notify the DPO when a data breach occurred which involve the personal data that was previously disclosed by Koh Kock Leong Enterprise Pte Ltd.
25. The Contractor should report to Data Protection Officer by the below channel:
INDEMNITY
26. The Contractor (The contractor who require Koh Kock Leong Enterprise Pte Ltd to disclose personal data for security clearance purpose) shall indemnify the Koh Kock Leong Enterprise Pte Ltd and its officers, employees and agents, against all actions, claims, demands, losses, damages, statutory penalties, expenses and cost (including legal costs on an indemnity basis), in respect of:
DATA PROTECTION OFFICER
27. 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 request by: