- As used in this Notice:
"client" means an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any 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:
(a) date of birth, marital status;
(b) Contact information, such as, your address, email address or telephone number;
(c) Photographs and other audio-visual information;
(d) Employment information; and
(e) Financial information, such as, credit card numbers, debit card numbers or bank account information.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data, unless:
(a) it is provided to us voluntarily by you directly or via an authorised representative. An Authorised representative includes your legal representatives, your service providers (for example, auditors, company secretaries, bankers, and any others), your employer or employee, or third-party sources such as government agencies, for example, the Inland Revenue Authority of Singapore. You and your authorised representative will be notified of the purposes for which the data is collected and you have provided your written consent prior 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. 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).
- We may collect and use your personal data for any or all of the following purposes:
(a) Existing client or potential client
Your personal information is processed as required or permitted by law and to give effect to your commercial transaction with us, including:
• Provision of services by us (for example, tax services, business advisory services, company secretarial services, payroll, and others);
• Communication and distribution of newsletters, articles, write-ups, updates and/or notification of upcoming events; and
• Administration purposes, including billing, payment and debt collection and for our Client Due Diligence process.
(b) Job applicants, current employee(s) and former employee(s)
We use your Personal Data for a variety of personnel/employee administration, work and general business management purposes, including but not limited to the following:
• To contact or communicate with you or send general or specific notices relating to or connected to your employment;
• To administer payroll and employee benefits (for example, leave entitlement, group insurance policy and/or employees provident fund contributions);
• To administer and maintain personnel records such as recruitment, termination and internal structuring/planning;
• For budget planning and reviewing of remuneration packages;
• To process appraisals and reviews; and
• To maintain medical leave, absence records and leave applications.
- 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 provide services to us (such as insurance companies, auditors, and any others) or to law enforcement agencies as required by law or pursuant to our contractual obligations.
- 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).
WITHDRAWING YOUR CONSENT
- 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. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- 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 it.
- 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 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 8 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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make: (a) an access request 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 amend 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. Please provide proof of your identity, address and sufficient information to enable us to identify you when submitting your request to us. On receipt of your request, we may comply or refuse your request to access or rectify your personal data and in such an event, we will notify you the reasons for such refusal.
- 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.
- 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, 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).
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks, we have introduced administrative, physical and technical measures, 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.
- 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 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- 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.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer, James C Wong, if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Telephone: +65 6227 8266
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with any other 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 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 use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : November 2019
Last updated : November 2019
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