Personal Data Protection Act
It is HSK Centre (Crestar) (“HSK”)’s policy to comply with all applicable primary and data protection laws in accordance with the Singapore’s Personal Data Protection Act 2012 (“PDPA”). HSK recognises the importance of the personal data that candidates, students and relevant public (collectively referred to as “the Public”) have entrusted to the organization. It is HSK’s responsibility to properly manage, protect and process personal data. Should the Public at any time, have any queries relating to personal data, they may contact HSK’s Data Protection Officer (“DPO”) at firstname.lastname@example.org.
A. Introduction To The PDPA
- “Personal Data” as defined under the PDPA refers to data collected, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organisation has or is likely to have access.
- The Public will be notified of the purposes that personal data is collected, used, disclosed and/or processed and obtain consent, unless an exception under the law permits that no prior consent is needed by HSK to collect and process personal data.
B. Purposes For Collection, Use, Disclosure And Processing Of Personal Data
The personal data which HSK collects may be used, disclosed and/or processed for:
- Assessing the Public’s suitability for exam registration or course enrolment;
- Facilitating examination-related and/or course-related matters such as tracking and managing attendance and academic performances, application and renewal of admission ticket;
- Providing information and/or updates related to HSK’s examinations, courses, products and services, marketing campaigns, promotions, benefits, and events by SMS, phone, email, fax, mail, website, social media and/or any other appropriate communication channels;
- Administering and processing of any payments, fee adjustments, insurance claims, refunds and waivers related to examinations, courses, products, services requested;
- Responding to any enquiries, requests or complaints and resolve any issues and disputes which may arise from any relationships with HSK;
- Conducting market research or surveys on HSK’s examinations, courses, products and/or services;
- Sharing of personal data with HSK’s business or corporate partners for development of examinations, courses, products and/or services or launch marketing campaigns;
- Processing of payments to finance department;
- Maintaining and updating of test centre records;
- Audit, risk managements and security purposes;
- Detecting, investigating and preventing fraudulent, prohibited or illegal activities and analysing and managing of commercial risk;
- Enabling HSK to perform its obligations, transfer, assign and enforce rights, interests and obligations under any agreements or documents that the company is a party of or entered into;
- Meeting or complying with any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to HSK;
- Enforcing or defending HSK and the Public’s rights, and to comply with obligations under the applicable laws, legislations and regulations; and/or
- Other purposes which HSK notifies at the time of obtaining the Public’s consent; and/or any purpose which are reasonably related to the aforesaid, (collectively referred to as “Purposes”);
As the Purposes for which HSK may or will collect, use, disclose or process the Public’s personal data depends on the circumstances at hand, such purpose may not appear above. However, HSK will notify the Public of such other purposes at the time of obtaining consent, unless processing of personal data without consent is permitted by the PDPA or by law.
C. Specific Issues For The Disclosure Of Personal Data To Third Parties
HSK respects the confidentiality of the personal data the Public has provided. HSK will not disclose the Public’s personal data to third parties without first obtaining consent to do so. However, there are situations that HSK may disclose the Public’s personal data to third parties without first obtaining the Public’s consent including, without limitation, the following:
- Cases in which disclosure is required or authorised based on the applicable laws and/or regulations;
- Cases in which the purpose of such disclosure is clearly in the Public’s interests, and if consent cannot be obtained in a timely way;
- Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of the Public or another individual;
- Cases in which the disclosure is necessary for any investigation or proceedings;
- Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- Cases in which the disclosure is to a public agency and such disclosure is necessary in the Public’s interests; and/or
- Where such disclosure without the Public’s consent is permitted by the PDPA or by law.
The instances listed above are not intended to be exhaustive. For more information, please visit http://statutes.agc.gov.sg. In the event where by HSK discloses the Public’s personal data to third parties with the Public’s consent, HSK will employ the best efforts to safeguard the Public’s personal data.
D. Access And Correction
The Public may request to update the personal data in HSK’s records by submitting a written request to the DPO through email or letter. For a request to update personal data, once HSK has sufficient information from the Public, HSK will:
- Provide or correct the Public’s relevant or personal data within 30 days. If HSK is unable to do so within the said 30 days, HSK will notify the Public of the soonest practicable time within which correction can be made. (Note: The PDPA exempts certain types of personal data from being subject to the Public’s correction request as well as provides for situations when correction need not be made by HSK despite the Public’s request); and
- Send the corrected personal data to organisations to which the personal data was disclosed by HSK within a year before the date the correction was made, unless the other organisation does not need the corrected personal data for any legal business purpose. Though, HSK may, if the Public gives consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by HSK within one (1) year before the date the correction was made.
E. Request To Withdraw Consent
- The Public may withdraw their consent for the collection, use and/or disclosure of their personal data by submitting their request to HSK’s DPO through email or letter.
- HSK will process the Public’s request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose the Public’s personal data.
- However, the Public’s withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that HSK will not be able to continue with the existing relationship with the Public and the contract that the Public has with HSK will have to be terminated.
F. Management Of Data (Accuracy, Completeness, Protection And Retention)
- HSK will take reasonable efforts to ensure that the Public’s personal data is accurate and complete. HSK will not be responsible for relying on inaccurate or incomplete data arising from the Public not updating HSK of any changes in their personal data that was initially provided.
- HSK will also put in place reasonable security arrangements to ensure that all personal data is adequately protected and secured. However, HSK cannot assume responsibility for any unauthorised use of the Public’s personal data by third parties.
- HSK will also put in place measures such that the Public’s personal data in HSK’s possession or under HSK’s control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
- If the Public’s personal data is to be transferred out of Singapore, HSK will comply with the PDPA in doing so. HSK will also take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the Act.
G. Complaint Process
The Public may contact HSK’s DPO through email or letter if they have any complaints or grievances with regard to the handling of personal data or HSK’s compliance with the PDPA.
H. Updates On Data Protection Policy
As part of HSK’s efforts to ensure that HSK properly manages, protects and processes the Public’s personal data, HSK will review the policies, procedures and processes from time to time.
HSK reserves the right to amend the terms set forth under this Data Protection Policy at HSK’s absolute discretion. All amended Data Protection Policy will be posted on HSK’s website.
The Public is encouraged to visit HSK’s website from time to time to ensure that they are well informed of HSK’s latest policies in relation to personal data protection.
I. Contact Information
Data Protection Officer
HSK Centre (Crestar)
587 Upper Serangoon Road
Crestar Building Singapore 534563