Personal Data Protection Policy

1. Introduction

1.1 Purpose of Policy
 
New Hope Community Services (New Hope CS) is committed to safeguarding the personal data entrusted to it by the individuals. This Policy sets out how New Hope CS uses, collects and disclose personal data about you so that we can serve you better. It also sets out how you can update us or request to be unsubscribed from our records.
 
1.2 Definitions
 
Personal Data
 
Personal data generally refers to data about an individual who can be identified from that data, in whatever form. It includes information such as individual’s name, identification number, address, mobile phone number, email addresses and photos and video images of the person (including CCTV images). Employee data of New Hope CS such as salaries, medical records and educational records is also recognised as personal data and is subject to all the obligations of the PDPA.

2. Policy Statement

New Hope CS will:

  • Comply with regulatory requirements as stated in the PDPA 2012;
  • Respect individual rights;
  • Be transparent and honest to the individuals whose data are held by us;
  • Provide training and support for staff and volunteers who handle personal data, so that they may confidently comply with this policy;
  • Properly document and protect personal data with appropriate security and keep personal data with trusted and authorised parties; and
  • Keep personal data for no longer than necessary.
3. Data Collection, Usage and Disclosure

3.1 Purpose for Information Collection
 
Personal data collected by New Hope CS is mainly to help us understand your needs so as to enable us to serve you better.
 
These purposes include the following:

  • To provide services such as transition shelters, food ration, life skills training, job training, HOPE programmes and social service;
  • To notify members, volunteers and donors of our events and programmes;
  • To assess our clients for administer grants, subsidy, referral programmes and services;
  • To comply with legal process or legal requirements of any government agencies;
  • To solicit donations from business owners, corporations, executives and existing donors;
  • To process job applications, recruitment and selection; and
  • Any other purpose relevant to NHCS objectives of which you will be notified and we will ask for your consent.

3.2 How Do We Acquire Your Personal Data?
 
Personal data is to be collected by fair, transparent and lawful means, without misleading or deceiving individuals as to the purposes for collection of personal data about them. New Hope CS may collect personal data from a number of channels, but are not limited to:

  • Application form(s) submitted by clients to New Hope CS for purpose of applying for New Hope CS’ services;
  • Job application form(s) for a job position in New Hope CS via online job portals, recruitment agencies and physical form(s);
  • Where an individual makes a donation to New Hope CS;
  • E-forms from website for volunteer registration, donations and enquiries;
  • Images and videos taken by representatives during New Hope CS events or from our CCTV cameras within our premises;
  • Where an individual submits his personal data for the purpose of volunteering; and
  • We may collect information such as your name, telephone number when you visit our New Hope CS’ office, for security purposes.

3.3 Consent
 
New Hope CS shall always seek consent from individual to collect, use or disclose the individual’s personal data, except in specific circumstances where collection, use or disclosure without consent is authorised or required by law.
 
New Hope CS may seek consent from the individual’s parents/ legal guardian/ donee on behalf of the individual if the individual is not able to provide consent. For example, minor or person without mental capacity.
 
New Hope CS may not be able to fulfil certain services if New Hope CS is not able to obtain consent to the collection, use or disclosure of certain personal data.

3.4 Deemed Consent
 
New Hope CS may assume individual has consented to collection, usage and disclosure of their personal data in situations where the individual provided information for obvious purposes.
 
New Hope CS may deem individual’s consent was obtained for personal data collected prior to 2nd July 2014 for the purpose of which the personal data was collected. The consent may include for New Hope CS usage and where applicable include disclosure.
 
New Hope CS need not seek consent from staff (including volunteers and part-time workers) for purposes related to the staff’s work in New Hope CS. However, staff’s consent shall be obtained if such purpose is unrelated to their work. Staff shall be informed that their personal data may be disclosed to public and arrangements may be made to limit such disclosure with mutual agreement.

3.5 Consent Withdrawal
 
Any individual may withdraw their consent to the use and disclosure of their personal data at any time, unless such personal data is necessary for New Hope CS to fulfil its legal obligations. New Hope CS shall comply with the withdrawal request, and inform the individual if such withdrawal will affect the services and arrangements between the individual and New Hope CS. New Hope CS may cease such services or arrangements as a result of the withdrawal.
 
Please email your request for withdrawal of consent to [email protected].

3.6 Notification Obligation
 
New Hope CS shall collect this personal data directly from the individuals. However, New Hope CS may also collect individual’s personal data from third parties i.e. referral agencies such as Family Service Centre provided the consent was obtain from the individual or required by law.
 
Prior or during collecting personal data, New Hope CS shall make known to the individual the purpose for which the personal data was collected, except when such personal data is provided by an individual for an obvious purpose (e.g. individual provided personal data to register for an event, as such the purpose is for that event participation).

3.7 Accuracy Obligation
 
New Hope CS shall make every reasonable effort to ensure that individuals’ information it keeps are accurate and complete. Individuals can notify New Hope CS via [email protected] if there are any changes to their personal data that is relevant to New Hope CS.

3.8 Data Disclosure and Transfer of Personal Data In and Outside Singapore
 
New Hope CS may disclose individual personal data to internal/external/overseas organisations for necessary and appropriate purposes. Such transfer shall be done in a manner that is secure and appropriate align with PDPA requirements.
 
Where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies.
 
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.

4. Security and Storage

4.1 Protection of Personal Data
 
All personal data held must be secured and protected against unauthorised access and theft.
 
New Hope CS shall ensure that:

  • Restriction of personal data access within the organisation;
  • Provide physical security to personal data records and files;
  • Personal computers and other computing devices that may access to personal data are password protected. Passwords are managed in accordance with industry best practices;
  • Personnel and other files that contain sensitive or confidential personal data are secured and only made available to staff with authorised access; and
  • 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.

4.2 Storage of Personal Data
 
New Hope CS shall take reasonable and appropriate security measures to protect the storage of personal data such as:

  • Making confidential on documents with personal records clearly and prominently;
  • Storing hardcopies of documents with personal records in locked file cabinet systems; and
  • Storing electronic files that contain personal data in secured folders.

4.3 Retention Limitation Obligation
 
New Hope CS shall retain individual’s personal data only for as long as it is reasonable to fulfil the purposes for which the information was collected for or as required by law.
 
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.

5. Access and Correction of Personal Data

We can provide and help you access your own personal data:

  • Request for personal copy – a nominal administrative fee will be charged; or
  • For update or correction.

Requests for personal data access or correction by individuals, including any enquires and complaints shall be submitted to New Hope CS in writing to the Data Protection Officer at the following address and contact information:

  • Attention: Data Protection Officer
  • New Hope Community Services
  • Blk 148 Yishun Street 11, #01-123, Singapore 760148
  • Email: [email protected]
  • Telephone: 63059620

We may refute your access in cases if and when such related personal data is under legal proceeding, no proper identification or request is carried out with suspected fraudulent intent.

6. Accountability Obligation

New Hope CS shall develop and publish data protection policy statements to inform staff, including part-time staff and volunteers, declaring the manner that their personal data are collected, used and disclosed. The data protection policy statements are made available to staff and the public in our website.

7. CCTV, Video Recording and Photography

CCTV, video footage and photos may constitute personal data if an identifiable individual is captured.

  • Appropriate notices shall be put up to inform that the premises are covered by CCTV video surveillance; and
  • Notices shall be put up to inform visitors and volunteers that photographs and videos taken may be used by New Hope CS for communication and publicity purposes in print or electronic media.
8. Data Breach Notification Obligation

Even with reasonable protection measures in place, there may be a possibility of a data breach. In the event the data breach is assessed to be notifiable, New Hope CS will notify the affected individuals as soon as practicable, at the same time or after notifying the Commission. If the breach warrants notification to the Commission, New Hope CS will make notification as soon as practicable but no later than three (3) calendar days.

9. Website Related Activities

9.1 Tracking of User Activity
 
Where we track user activity, we will document this in our data inventory, and disclose such activity in our External Privacy Notice.

9.2 Use of Cookies
 
We use "cookies" to collect information about your activity on our web site. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. You can instruct your browser to refuse all cookies or to indicate them when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

9.3 Links to Other Sites
 
Our website may contain links to other websites that are (operated/not operated)by us. If you click on a third party link, you will be directed to that third party's website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services.

10. Policy Review

The Personal Data Protection Policy shall be maintained and updated by the Data Protection Officer, reviewed and approved by the Management in a timely manner but shall review at least yearly.
 
We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page. Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.

11. Contact Us

If you have any questions about our collection, use, and/or disclosure of personal data about you, feedback regarding this Policy, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at [email protected].
 
Any query or complaint should include, at least, the following details:
 
Your full name and contact information
 
A brief description of your query or complaint
 
We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.

Policy approved and effective date: Nov 2023

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New Hope Community Services HQ
Blk 148 Yishun Street 11, #01-123
Singapore 760148

Tel : +65 6305 9620
Fax : +65 6755 3684

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