DATA PROTECTION POLICY
This Data Protection Policy (“Policy”) sets out the basis which Coleman College Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act 2012 (“PDPA”). 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 process personal data for our purposes.
1.1 As used in this Notice:
a) “customer” means an individual,whether as a student, employee, alumnus, donor or service provider, etc
i) has contacted us through any means to find out more about any goods or services we provide, or
ii) may, or has, entered into a contract with us for the supply of any goods or services by us; and
b) “personal data” means data, whether true or not, about a customer who can be identified:
i) from that data; or
ii) from that data and other information to which we have or are likely to have access.
1.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include and not limited to your name, identification number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information (such as CCTV recordings), employment information and financial information such as credit card numbers, debit card numbers or bank account information.
1.3 Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
2. COLLECTION, USE AND 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 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).
2.2 When you visit our website, you may be providing us with the following information:
a) personal data you voluntarily choose to disclose to us, e.g., your name, email addresses and telephone number which you provide to us;
b) personal data of your parents or legal guardian in the case that you are currently under 18 years of age and have obtained consent from your parents or legal guardian to do so; and
c) website use information collected on an aggregate basis as you and others browse our website.
2.3 We may collect and use your personal data for any or all of the following purposes:
a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
b) verifying your identity;
c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
d) managing your relationship with us;
e) processing payment or credit transactions;
f) sending you marketing information about ourgoods or services including notifying you of our new academic pathways, new university partners, social media campaigns, marketing events, initiatives and promotions,and other promotions;
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 purposes for which you have provided the information;
i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
j) any other incidental business purposes related to or in connection with the above.
2.4 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 goods or services requested by you; or
b) to third party service providers, external agents and other organisations we have engaged to perform any of the functions listed in clause 6 above for us.
We do not sell, trade or rent your personal data to other parties.
2.5 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).
3. WITHDRAWING YOUR CONSENT
3.1 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.
3.2 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 fifteen (15) business days of receiving it.
3.3 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 goods or 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 3.1 above.
3.4 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.
4. ACCESS TO AND CORRECTION OF PERSONAL DATA
4.1 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.
4.2 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.
4.3 We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing within thirty (30) business 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
5. PROTECTION OF PERSONAL DATA
5.1 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 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.
5.2 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.
6. ACCURACY OF PERSONAL DATA
6.1 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.
7. RETENTION OF PERSONAL DATA
7.1 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.
7.2 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.
8. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
8.1 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.
9. ADDITIONAL INFORMATION TO DEAL WITH THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (EU) 2016/679 (“GDPR”)
9.1 This section applies only if a particular circumstance or activity applicable to Coleman College requires the application of the GDPR. Subject to the aforesaid, in such cases, this section would apply to residents of the European Union only.
9.2 Generally, we process personal data on the basis of consent. Apart from consent, under the GDPR, we may also lawfully process your personal data on one or more of the following bases:
9.3 Lawful basis for processing
a) The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
b) Process your personal data on the basis of a balance of interests to pursue our or a third party’s legitimate interests. This is carried out for one or more of the purposes set out at section 2 of this document.
c) Further, we may process your personal data for the legitimate interests of promoting the good of Coleman College and/or graduates’ community, and maintaining Coleman College’s relationship with its former students (i.e. graduates) to grow the college spirit in its students and former students.
d) Necessary for compliance with a legal obligation to which Coleman College is subject.
e) Necessary in order to protect the vital interests of the data subject or of another natural person.
f) Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Coleman College.
Generally, we process personal data on the basis of consent. Apart from consent, under the GDPR, we may also lawfully process your personal data on one or more of the following bases:
9.4 We practise data minimisation and strive to collect only what is necessary in relation to the purposes for which such personal data is processed and to maintain the relevant relationship between us such as the student relationship in the case where you are a student. The consequence of not providing such requested personal data may result in our inability to start that relationship with you, to maintain that relationship with you or to provide you with our products or services.
9.5 Where your personal data is transferred to a country for which the European Commission has not made an adequacy decision, we will take appropriate steps to ensure that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to protect the transferred personal data. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer.
9.6 Where the GDPR is applicable, you have the following rights (subject to any exceptions under the GDPR):
a) The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
b) The right of access; this is your right to see what data is held about you by a Data Controller.
c) The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
d) The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
e) The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
f) The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
g) The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
h) Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.
9.7 You also have the right to lodge a complaint with the local data protection authority or the European data protection authority applicable to you if you believe that we have not complied with applicable data protection laws.
9.8 In general, we do not use automated individual decision-making for the formation and management of your relationship with us. If we should rely on such processing in a particular situation, we will do so in accordance with the GDPR.
10. DATA PROTECTION OFFICER
10.1 You may contact our Data Protection Officer 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: firstname.lastname@example.org
11. EFFECT OF NOTICE AND CHANGES TO NOTICE
11.1 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.
11.2 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.