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Data Protection Notice for Employees

This Data Protection Notice (“Notice”) sets out the basis which Montfort Care (“Montfort Care”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of persons in accordance with the Personal Data Protection Act (“PDPA”) and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission (PDPC) of Singapore. 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.

Application of this Notice

1. This Notice applies to all persons engaged in a contract of service with us (whether on a part-time, temporary, or full-time basis), and interns and trainees working at or attached to us (collectively referred to as “employees”), and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).
2. For the purposes of this Data Protection Notice, “Personal Data” shall mean data (in manual, electronic or other form), 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 an organisation has or is likely to have access.

3. Personal data which we may collect in the context of your employment with us includes, without limitation, your:

   3.1. name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;

   3.2. mailing address, telephone numbers, email address and other contact details;

   3.3. employment and training history;

   3.4. salary information and bank account details;

   3.5. work-related health issues and disabilities;

   3.6. records on leave of absence from work;

   3.7. photographs and other audio-visual information;

   3.8. performance assessments and disciplinary records; and

   3.9. any additional information provided to us by you as a job applicant (that is, prior to being engaged as an employee).

4. 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

5. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), 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 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. You confirm that, where you have provided personal data of your Next of Kin or other individuals (e.g., for emergency contact purposes), you have obtained their consent to provide their personal data to us for the relevant purposes. 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).

6. 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:
   6.1 To respond to an emergency that threatens your life, health and safety or of another individual; and
   6.2 Necessary in the national interest, for any investigation or proceedings.

7. Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
   7.1. performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
   7.2. all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
   7.3. managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
   7.4. assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
   7.5. ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
   7.6. performing obligations under or in connection with the provision of our goods or services to our clients;
   7.7. with your consent, disclosing to third party service providers, agents, and other organisations we have engaged to perform any of the functions listed in this paragraph 7 for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential;
   7.8. facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
   7.9. facilitating our compliance with any laws, customs and regulations which may be applicable to us.

8. 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).

9. You have the right of choice regarding the collection, usage and disclosure of your personal data. If you choose not to provide us with any of your personal data requested, you may do so by writing to hr@montfortcare.org.sg. 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 your employment with us. 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).

Withdrawal of 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 in writing. If you wish to withdraw your consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed in paragraph 7 above, you may do so by writing to hr@montfortcare.org.sg.

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 to 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 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.
12. 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 continue your employment with us. 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 paragraph 10 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 disclosure without consent is permitted or required under applicable laws.

Access to and Correction of Personal Data

14. You may access your personal data via Prosoft System.
15. If you wish to make (a) an access request for access to a copy of the personal data not stored on HR system 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 or via email to hr@montfortcare.org.sg or by any other means made known to you during your employment.
16. We will respond to all personal data requests relating to withdrawal of consent, access, and correction as soon as reasonably possible. 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).
17. 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.

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 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. When we disclose your personal data to third parties in line with the purposes mentioned in paragraph 7, 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.

Accuracy of Personal Data

21. 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.

22. 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 emailing to hr@montfortcare.org.sg.

Retention of Personal Data

23. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were 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 purposes for which the personal data were collected and are 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.

Cross-border Transfers of Personal Data

26. Unless for business-related needs, we generally do not transfer your personal data to other jurisdictions. 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.

Human Resources and Data Protection Officer Contact Information

27. You may contact hr@montfortcare.org.sg, or our DPO at dpo@montfort.org.sg call us at +65 64460330 if you have any enquiry, feedback or complaint regarding our personal data protection policies and procedures.

Effect of Notice and Changes to Notice

28. This Notice 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.
29. 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 employment with us constitutes your acknowledgement and acceptance of such changes.

Effective: 1 June 2025

Last Updated: 1 June 2025