Privacy Notice

Montfort Care respects and values the privacy of our clients, partners, donors, volunteers and potential employees. Please read our Privacy Policy (“Policy”) carefully to understand how we may collect, use, disclose, or process your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).

1. Personal Data

1.1 “Personal Data” refers to any 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 we have or are likely to have access.

1.2 Some examples of Personal Data include names, identification numbers such as NRIC and passport numbers, telephone numbers, mailing or email addresses or photographs of the individuals.

1.3 Other terms used in this Notice shall have the meanings given to them in the Singapore Personal Data Protection Act (where the context so permits).

2. Collection, Use & Disclosure of Personal Data

2.1 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; or

(b) collection and use of the Personal Data is permitted or required by law.

2.2 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).

2.3 If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent that you have obtained the consent of such third party to provide us with their Personal Data. You hereby agree to indemnify and hold us harmless from and against any and all claims by such third party relating to our collection, use, disclosure, or processing of such Personal Data in accordance with the terms of this Policy.

2.4 We may collect your Personal Data for any or all of the following purposes:

(a) Administering services, including but not limited to, our clients, engaging volunteers and donors, working with partners, employment matters, reporting to proper authorities and other relevant and reasonable work that are necessary to facilitate or to enhance service provision;

(b) Performing obligations in the course of or in connection with our provision of the services requested by you;

(d) Responding to, handling and processing queries, requests, applications, complaints and feedback from you;

(e) Managing your relationship with us;

(f) Processing payment or credit transactions;

(g) 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;

(h) Any other incidental business purposes related to or in connection with the above.

2.5 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.

2.6 In providing you with a service, we may sometimes need to disclose your Personal Data to others. It is generally not our policy to disclose your Personal Data to external organisations unless we have your consent and/or are required to disclose your Personal Data as required in the normal course and scope of our service provision to you, and/or for contractual, legal and regulatory requirements. However, we may disclose your Personal Data:

(a) Where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or

(b) To third-party service providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 2.4 above for us.

2.7 The purposes listed in the above clauses may continue to apply even after 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).

3. Right of access & correction of Personal Data

3.1 If you wish to:

(a) make 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) make a correction request to correct or update any of your Personal Data which we hold about you,

you may submit your request in writing or via email to our Data Protection Officer.

3.2 Please note that a reasonable fee may be charged for an access request. We will inform you of the fee before processing your request.

3.3 We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, then we will inform you in writing within thirty (30) days of the time by which we would be able to respond to your request.

3.4 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).

3.5 The purposes listed in clause 2.4 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).

3.6 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.

4. Withdrawal of consent

4.1 The consent that you provide for the collection, use, and disclosure of your Personal Data will remain valid until such time as withdrawn by you in writing. You may withdraw consent and request us to cease using and/or disclosing your Personal Data for any or all of the purposes above by submitting your request in writing or via email to our Data Protection Officer.

4.2 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 ten (10) business days of receiving. 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.

4.3 Please note that depending on the nature and scope of your request to withdraw your consent, we may not be in a position to continue providing our 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 4.1.

4.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.

5. Access to and correction of Personal data

5.1 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 in writing or via email to our Data Protection Officer at the contact details provided below.

5.2 We will respond to your request as soon as reasonably possible. 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. Should we not be able to respond to your request within thirty (30) days after receiving your request in writing (including both electronic and non-electronic methods), 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).

5.3 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.

5.4 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.

6. Protection of Personal Data

6.1 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.

6.2 If there is a need to disclose your Personal Data to third parties in line with the purposes mentioned in clause 2.4, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.

6.3 However, please note 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.

7. Retention of personal data

7.1 We may retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws in Singapore.

7.2 We will cease to retain your Personal Data, or remove the means by which the data may be associated with you, as soon as reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and retention would no longer be necessary for legal or business purposes.

8. Accuracy of Personal Data

8.1 We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.

8.2 We will rely on your Personal Data to provide services to you. You shall ensure that the information provided by you is correct, complete and updated at all times.

9. Transfer of Personal Data Outside Singapore

9.1 We generally do not transfer your Personal Data to countries outside of Singapore.

9.2 However, where we do so, we will take steps to ensure that your Personal Data continues to receive a standard of protection under the other country’s laws which is at least comparable to that provided under the PDPA.

10. 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.

11. Changes to Policy

We reserve the right to modify or change this Policy at any time. Please refer to our website from time to time for any changes and/or updates to our Policy.

12. Contact Us

You may contact our Data Protection Officer in relation to any of the above matters, or if you have any general enquiries or feedback regarding this Policy. The Data Protection Officer is contactable at: dpo@montfortcare.org.sg.

This privacy policy was last updated on 30th September 2024.