ACRES PERSONAL DATA PROTECTION ACT
PRIVACY POLICY
1. INTRODUCTION
A. THE PERSONAL DATA PROTECTION ACT
The Personal Data Protection Act (Act No. 26 of 2012) (“PDPA”) regulates the collection, use and disclosure of an individual’s personal data. The general rule laid out by the legislation is that personal data can only be collected, used and / or disclosed with the consent of the individual concerned.
The PDPA has been implemented in two stages. The Do Not Call (“DNC”) registry came into force on 2 January 2014. The remainder of the provisions, including those pertaining to the collection, use and disclosure of personal data, came into force on 2 July 2014.
B. RELEVANCE OF THIS EXTERNAL POLICY
The PDPA applies to all organisations, including voluntary welfare organisations such as ACRES. It requires ACRES to put into place practices and policies to meet the prescribed data protection standards. ACRES is liable for all the acts committed by its employees and volunteers, unless reasonable steps have been taken by ACRES to prevent these persons from violating the Act.
This external policy therefore aims to inform the general public about how ACRES complies with the PDPA. It also provides a set of practical steps that people may take to gain access to, or make corrections to their personal data provided to ACRES. These steps also allow them to withdraw their consent to the collection, use or disclosure of their personal data.
C. PERSONAL DATA
In this Data Protection Policy (“Policy”) and under the PDPA, “personal data” refers to any data (whether true or not) about an individual who can be identified [1] from that data; or [2] from that data and other information to which we have or are likely to have access.
Examples of such personal data may include a person’s:
- name, NRIC, passport or other identification number;date of birth;
- contact details such as telephone number(s), mailing address(es), and email address(es);
- education details;
- images, videos, and voice recordings;
- employment and financial details; or
- any other information relating to any individuals which may have been provided to ACRES, in any form.
In this Policy, “we”, “us”, “our” or “ACRES” refers to the Animal Concerns Research & Education Society, “you”, “your” or “yours” refers to the persons to whom this Policy applies.
2. EXTERNAL GUIDELINES
A. ACRES’S COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
ACRES is committed to adhering to its legal obligations under the PDPA. This means that ACRES will do its best to comply with the general rule laid out by the PDPA that personal data can only be collected, used and/or disclosed with the consent of an individual (subject to the exceptions and on the terms provided in the PDPA).
Note: The information in this Policy merely provides an overview of ACRES’s obligations under the PDPA. This Policy is not a representation by ACRES that is meant to create any private law obligation. ACRES’s precise legal obligations may be found in the PDPA, the Personal Data Protection Regulations 2014 and any other subsidiary regulations, notices or guidelines in force. ACRES may, from time to time, update this Policy to reflect any changes in legal or regulatory requirements.
B. COLLECTION
In general, ACRES collects personal data when:
- you submit any form be it online or hardcopy (such as registration, application, casework, membership, consent, public permission, or donation forms);
- you enter into any agreement with ACRES;
- you provide other documentation or information in respect of your interactions, and transactions with ACRES, or when you use ACRES’s services (for example, when ACRES’s needs to issue a receipt to you);
- you interact with ACRES staff, volunteers, and other representatives (for example, via telephone calls, email, fax, letters, fax, and face-to-face meetings);
- you request that ACRES contact you, or be included in an email or other mailing list kept by ACRES;
- you respond to ACRES’s request for additional personal data through other initiatives;
- you submit an employment, internship or volunteer application, or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment;
- ACRES takes your photographs or videos when you attend ACRES events;
- ACRES seeks information about you and receives your personal data in connection with your relationship with ACRES (such as for animal wildlife services or employment applications), for example, from public agencies or the relevant authorities; and/or
- you submit your personal data to ACRES for any other reason.
Accuracy: ACRES will make reasonable efforts to ensure that the personal data ACRES collects is accurate and complete. Please help ACRES by ensuring that all personal data that you submit is complete and accurate. If you fail to do so, ACRES may be unable to provide you with the services you have requested.
If ACRES is likely to use your personal data to make a decision that affects you, or if ACRES is likely to disclose your personal data to another organisation, ACRES will make reasonable efforts to ensure that personal data collected by or on behalf of us is accurate and complete.
Security: ACRES will protect the personal data by making reasonable security arrangements. However, ACRES cannot completely guarantee the security of your personal data.
C. PURPOSES OF COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
In general, ACRES may collect, use and disclose personal data for the following purposes, amongst others:
- responding to, processing and handling complaints, queries, requests, feedback, tip offs and suggestions;
- donor engagement;
- assisting and contacting parties in relation to the services they have requested;
- liaising with the relevant authorities in relation to the services requested;
- contacting parties in relation to events ACRES is hosting;
- research and advocacy purposes in relation to wildlife and conservation issues;
- to provide information to the relevant funding agencies;
- ACRES’s internal record keeping purposes;
- applying for staff insurance;
- for use in ACRES publications and publicity material, or to send out ACRES publications and publicity material;
- contacting volunteers regarding their tasks, or regarding future volunteering opportunities; or
- complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities and agencies (including but not limited to, the submission of audited accounts).
ACRES may also share or refer your personal data to third party providers of services, such as for donation and receipt processing.
ACRES will seek your prior consent for any disclosure of your personal information in relation to these purposes and for any other purpose that is not listed above.
ACRES will retain your personal data for as long as the purpose(s) for which it was collected remain(s) valid, or for as long as the personal data is necessary for ACRES’s legal or business purposes.
D. CONTACTING ACRES: FEEDBACK, COMPLAINTS, ACCESS AND CORRECTION OF YOUR PERSONAL DATA, AND WITHDRAWAL OF CONSENT
If you:
- have any questions or feedback about how ACRES handles personal data;
- have any complaints about how ACRES has handled your personal data;
- wish to obtain access or make corrections to your personal data that ACRES has; or
- wish to withdraw your consent to ACRES’s use of your personal data,
You may contact ACRES’s Data Protection Officer:
Anbarasi Boopal
Co-CEO (Advocacy)
info@acres.org.sg
Please identify yourself and indicate the personal data that the request concerns. ACRES will strive to respond to each request as soon as reasonably possible and as accurately and completely as necessary. However, please note that ACRES may refuse your request under certain circumstances as laid out under the PDPA.
Note on Withdrawal of Consent: If you withdraw your consent to the use of your personal data, depending on the nature of your request, ACRES may not be able to continue providing its services or performing its contractual obligations to you. Any withdrawal of consent may also result in the termination of any agreements or arrangements you have with ACRES and you being in breach of your contractual obligations or undertakings. ACRES reserves its legal rights and remedies in such an event.