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. If you wish to make any inquiries regarding this Policy, you should contact our Data Protection Officer in any of the ways specified in clause 26 below.
- As used in this notice:
- “client” means an individual who (a) has contacted us through any means to find out more about any goods and/or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods and/or services by us; and
- “personal data” means data, whether true or not, about a client 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.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information (such as your address, email address or telephone number), nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use, and Disclosure of Personal Data
- We collect personal data about individuals such as:
- our clients, potential clients and their representatives
- our suppliers, potential suppliers and their representatives;
- contractors and subcontractors and potential contractors and subcontractors
and their representatives in relation to providing goods and services to us;
- any other person who comes into contact with CFS.
- Generally, we collect personal data when it is provided to us:
- voluntarily by you directly; or
- in circumstances where our collection and use of personal data without consent is permitted or required by the PDPA or other data protection laws.
- We may also collect personal data about you from third party and other sources such
- a third party who has been duly authorised by you to disclose your personal data to us; or
- publicly available sources of information.
- We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been listed in this Policy or otherwise notified to you (except where permitted or authorised by law).
- We may collect and use your personal data for philanthropy programmes; fundraising programmes; corporate giving programmes; CFS grants and CFS news, events, publications, media releases, and reports, as well as for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- sending you marketing information about our goods or services including notifying you of our marketing events, initiatives, and other promotions;
- 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;
- any other purposes for which you have provided the information;
- 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
- any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
- 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
- to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 8 above for us.
- 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).
- If you choose not to provide your personal data to us for the purposes set out in this Policy, or if we are unable to collect the personal data we require, we may not be able to provide you with requested information, goods and services or to effectively conduct our relationship with you.
- 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, or (c) withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided at clause 26 below.
- Where we have received a request from you withdrawing your consent to the use and/or disclosure of your personal data for any or all of the purposes listed above, we will cease to use and/or disclose your personal data in accordance with your request within 30 business days of receiving said request. 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 providing our goods or services to 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 writing in the manner described in clause 12 above. 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.
- 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.
- Please note that there may be some legal or administrative reasons to deny access. If we refuse your request to access your personal data, we will provide you with reasons for the refusal where we are required by law to give those reasons.
Protection of Personal Data
- 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 and encryption 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.
- 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 Personal Data
- 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 at Clause 26 below.
Retention of Personal Data
- 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.
- 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.
Transfer of Personal Data outside Singapore
- Some of your personal data may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
- our offices or related entities are overseas;
- we outsource certain activities overseas;
- transactions, information, services or products have an overseas connection; or
- our computer systems including IT servers are located overseas.
You consent to the collection, use, storage, and processing of your personal data outside Singapore as set out in this Policy.
- To the extent that any of the communication means which you have provided us with (which may include your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy, by any means of indication, you hereby grant CFS your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated in clause 8.
- If you provide your consent to receiving marketing materials from third parties, we will provide them with your personal data to enable them to identify opportunities and send information and advertising material to you. The personal data we provide may include your name and contact details, as well as other information relevant to the third party’s goods or services. Our disclosure of such personal data may be for the purposes of enabling the relevant third party to direct market to you on their own behalf, not on our behalf. You can request that we stop sharing your information with third parties for these purposes at any time by contacting us using the details specified in clause 26. However for third parties with whom we have already shared your personal data in accordance with this paragraph, you may need to contact those third parties directly if you’d like to no longer receive direct marketing from each of them.
- If you do not wish to receive marketing materials from CFS or third parties, you may opt out by sending a clearly worded email to the Data Protection Officer via the email address provided in clause 26 below or by clicking on the “Unsubscribe” or subscription preferences link in a direct marketing email that you have received from us.
- Your request shall be processed within a reasonable time. However, please note that in such an event we may not be in a position to continue to provide our services to you, administer any contractual relationship in place, and this may also result in the termination of any agreements with us and our legal rights and remedies in such event are expressly reserved.
Data Protection Officer
- You may contact our Data Protection Officer if you:
- have any enquiries or feedback on our personal data protection policies and procedures;
- wish to make any request to access or update your personal data held by us;
- wish to opt out of direct marketing;
- wish to withdraw your consent to our use and/or disclosure of your personal data for any or all of the purposes listed above, at email@example.com with a subject line beginning with “Data Protection”.
- If your personal data has been provided to us by a third party (e.g. your authorised representative), you should contact that individual to make such queries, complaints and access and correct requests to CFS on your behalf.
- We will keep a record of your request to exercise your rights and our response to your request in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies at clauses 19 to 20 above.
Effect of Policy and Changes to Policy
- This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Last updated on 5 November 2021