Personal Data Protection Act
We at Radiance60 respect the privacy and confidentiality of personal data in our possession or under our control; the personal data of our Clients, Partners, Consultants, Contractors, Service Providers, Outsourced Third-Parties and others who have business dealings with us.
We have implemented policies and practices to safeguard the collection, use, disclosure, storage and other processing of personal data provided to us.
How We Collect Your Personal Data
We collect your personal data in the following ways:
Respond to our events or campaigns
Provide feedback to us on our quality of service or your user experience
Provide your personal information relating to the courses/programs conducted by us
Visit our websites and leave behind your contact information
Communicate with us via emails or written correspondences
How We Use Your Personal Data
We use the personal data we have collected about you for one or more of the following purposes:
Student enrolment in long and short courses
Communicate with enquirers and analyse website visitors
Notify you about our courses, programs and special events
Respond to enquiries, update requests and feedback on user experience
Monitor the movement of visitors to our physical premises for safety and/or security purposes
Process job applications, recruitment and selection
Carry out our obligations arising from any contracts entered into between you and us
Comply with legal obligations and regulatory requirements
Who We Disclose Your Personal Data To
We disclose some of the personal data we have collected about you to the following parties or organisations outside Radiance60:
Regulatory Authorities e.g. SSG, IMDA, ICA
External advisors e.g. auditors, lawyers, consultants
Insurance Companies
IT/Technical Support, IT Service Providers
Webhosting Companies, Cloud Service Providers
Banks, Payment card processing companies
Commercial Service and Training Providers
Other government agencies (e.g. Ministry of Manpower, Ministry of Health, ICA, SSG etc)
How We Manage the Collection, Use and Disclosure of Your Personal Data
a.Obtaining Consent
To the fullest extent required by the Personal Data Protection Act (PDPA), before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purpose.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for a stated purpose. There are different forms of deemed consent, namely (a) deemed consent by conduct, (b) deemed consent by contractual necessity; and (c) deemed consent by notification.
b.Third-Party Consent
If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.
c.Withdrawal of Consent
If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us or our clients.
Your request for withdrawal of consent can take the form of an email or letter to us.
How You Can Access and Make Correction to Your Personal Data
You may write in to us, based on reasonable grounds, to find out how we have been using or disclosing your personal data. We are obligated under the PDPA to allow you access to your personal data of the past one year, and to make any correction if there is any error or omission. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification documents.
We will endeavor to fulfill your request within 30 days, with an estimate of the fee for processing the request (if applicable). If we are not able to do so within 30 days, we will notify you of the additional time required.
We will send the corrected personal data to every other organisation to which the personal data was disclosed by Radiance60 within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose, or if you so consent, only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
How We Ensure the Accuracy of Your Personal Data
We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we may do a verification exercise with you to update us on any changes to your personal data.
How We Protect Your Personal Data
We will take the necessary security arrangements to protect your personal data that is in our possession to prevent unauthorised access, use, disclosure, or similar risks. We will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
External Data Intermediaries who process and maintain your personal data on our behalf will be bound by contractual information security arrangements we have with them.
How We Retain Your Personal Data
We will not retain any of your personal data under our charge when it is no longer necessary for any business or legal purposes. Based on our Document Retention Policy, we will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.
How We Transfer Your Personal Data
If there is a need for us to transfer your personal data to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.
How We Handle Queries and Complaints
If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer at:douglas@radiance60.com.
Any query or complaint should include, at least, the following details:
1.Your full name and contact information
2.Brief description of your query or complaint
We treat such queries and complaints seriously and will deal with them confidentially and within a reasonable time.
Review of Policy for External Data Protection Statement
This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months. The review will be undertaken by the Data Protection Officer (DPO) together with the Data Protection Managers (DPMs).