Privacy Statement/Data Protection Policy
Last Updated: 17 November 2017
Babes Pregnancy Crisis Support Ltd (we, us, our, etc.) are committed to safeguarding your personal data.
This data protection policy gives you information about how we collect, use and disclose your personal data while recognising both your right to protect your personal data and our need to collect, use or disclose it for purposes that we believe are reasonable and appropriate in the circumstances of our charitable work.
This policy applies to the personal data of all individuals who are our service users, our donors, our employees (including volunteers), and visitors to our website at www.babes.org.sg.
If you are not in any of these categories but we collect, use or disclose your personal data in the course of our charitable work, this data protection policy will apply to that personal data in the same way as it applies to the personal data of the categories of individuals mentioned above.
1. What is personal data?
“Personal data” is data, whether true or not, about you which allows us to identify you:
(a) from that data, or
(b) from that data and other information to which we have or are likely to have access.
Examples of Personal Data are your name and your personal identification number (National Registration Identity Card or passport number), home address, personal email address and mobile telephone number. Please note that the Personal Data Protection Act 2012 does not apply to business contact information not provided solely for your personal purposes.
2. Why do we collect, use or disclose personal data?
We collect personal data from or about our service users and our potential service users and from our donors, employees and other individuals. We use and/or disclose that personal data so that we are able to provide our services (which are described on our website) efficiently and effectively and so that we can comply with our legal obligations.
3. How do we collect, use and disclose of personal data?
Where possible, we collect personal data directly from you. We do this in various ways, including telephone and in-person meetings and interviews, forms and questionnaires. We do not collect any personal data from you unless you voluntarily provide it to us. For example, you may provide us with your personal data by completing and submitting the Volunteer Registration form on our website. If you are only browsing our website, we do not capture any data that allows us to identify you.
If at any time you would prefer not to provide some personal data that we request, please let us know. We will then explain our purpose for collecting that personal data. If you still do not wish to provide it, we will discuss with you whether or not we can proceed without it. We may not be able to proceed without it.
We collect, use, or disclose personal about you only if:
- you give, or are deemed to have given, your consent under the Personal Data Protection Act (PDPA) to us collecting, using or disclosing that personal data, or
- collection, use or disclosure by us of that personal data without your consent is required or authorised under the PDPA or any other written law.
Where we ask you to consent to us collecting, using or disclosing your personal data, we will first inform you of our purposes for doing so. We will not use or disclose your personal data for any other purposes without first informing you of the additional purposes and getting your consent to us doing so for the additional purposes.
The purposes for which you may provide your personal data to us include:
- making a telephone call to us or sending us an SMS or email to
- ask for support
- refer us to someone in need of our support
- enquire about our services
- submitting a Volunteer Registration
- making a donation
- applying for employment.
We only use your personal data for the purposes for which it was given, so we will only use it to:
- respond to your request, referral or enquiry
- respond to your information requests about us and our services
- review and respond to your Volunteer Registration
- process your donation and, with your consent, recognise you publicly for your donation
- assess and respond to your employment application.
We may also use your personal data to send you updates about our work, solicit donations, invite you to events and provide you with information we think may be of interest to you in relation to our services (ancillary purposes). In those circumstances, we may disclose your personal data to other companies and individuals retained by us to perform certain functions on our behalf (e.g. companies and individuals who process donations and/or conduct promotional activities). Those third parties may be provided with access to your personal data to perform their functions but may not use your personal data for any other purpose.
By providing us with your personal data, you consent to our use of your personal data for ancillary purposes. You may withdraw your consent by reasonable notice to us.
In some circumstances, you are deemed to have consented to us collecting, using or disclosing your personal data for a purpose. For example, if you pose for a photograph by our photographer at one of our events or if you fill up a job application form and send it to us, you are deemed to have consented to us collecting, using or disclosing your personal data that is in the photograph (that is, your image) or the job application.
We may collect personal data about you from another individual or organisation if you have given that other individual or organisation consent that allows it to disclose personal data to us. We will use or disclose it only for the purposes for which the other individual or organisation disclosed it to us.
We are permitted by the PDPA to collect, use or disclose personal data about you without your consent in various circumstances that include the following:
- if it is publicly available information (such as a photo that is taken in a place that is open to the public)
- if it is disclosed to us by a public agency and our collection is consistent with the purpose of the disclosure by the public agency
- if it was provided to us by another individual to enable us to provide a service for the personal or domestic purposes of that other individual (for example, where a service user provides us with personal data about her partner, her family or her other connections so that we are able to help her better)
- if there is an emergency that threatens your or another person’s life, health or safety
- where the disclosure is related to law enforcement or where the collection, use or disclosure is in connection with certain legal issues.
If you would like more information about the circumstances in which we may collect, use or disclose your personal data you without your consent, please contact our Data Protection Officer.
4. How can you withdraw your consent?
On giving us reasonable notice, you may at any time withdraw any consent you have given, or are deemed to have been given, to us collecting, using or disclosing your personal data for any purpose. Any notice of withdrawal of consent should be given in writing (which includes email) sent to our Data Protection Officer.
The consequences of you withdrawing consent to us collecting, using or disclosing your personal data for any purpose may be onerous for you. Therefore:
- we may require you to provide proof of your identity, and
- we will inform you in writing (which may be by email) of the likely consequences of withdrawing your consent for the specified purpose.
If you still wish to withdraw your consent, we will act on your request and stop collecting, using or disclosing your personal data, unless doing so without your consent is required or authorised under the PDPA or other written law. We will also cause any and all of our data intermediaries to stop collecting, using or disclosing your personal data.
In addition, we will stop keeping documents containing your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable for us to assume that retention is no longer necessary for our legal or business purposes.
5. How can you access your personal data and information about its use?
On request by you, we will as soon as reasonably possible provide you with:
- personal data about you that is in our possession or under our control and
- information about the ways in which we have, or may have, used or disclosed that personal data within a year before the date of your request
Your request to us should be made in writing (which includes email) sent to our Data Protection Officer. We may require you to provide proof of your identity.
There are some circumstances where we are not required to provide you with information, and others where we are not allowed by the PDPA to do so. In some circumstances, we may be able to provide you with limited information. You may obtain information about all of these circumstances from our Data Protection Officer.
6. Correction of errors in, or omissions from, your personal data
You may request us to correct an error or omission in your personal data that we hold or that is under our control. Your request to us should be made in writing (which includes email) sent to our Data Protection Officer. We may require you to provide proof of your identity and/or documents or other evidence supporting your request.
There are some circumstances where we do not make a correction and other circumstances where we are not required to act on such a request. You may obtain information about these circumstances from our Data Protection Officer.
Unless we are satisfied on reasonable grounds that a correction should not be made, we will correct your personal data as soon as practicable. We will also send the corrected personal data to every other organisation to which we have disclosed it within a year before the date we made the correction (unless that other organisation does not need the corrected personal data for any legal or business purpose). Alternatively, with your consent, we will send the corrected personal data only to specific organisations as agreed with you.
Another organisation that has disclosed your personal data to us might notify us that it has corrected it. If this happens, unless we are satisfied on reasonable grounds that we should not make the correction, we will correct your personal data that is in our possession or under our control.
7. Accuracy of personal data
We make reasonable efforts to ensure that personal data that we collect about you or that is collected on our behalf is accurate and complete if:
- we are likely to use it to make a decision that affects you, or
- we are likely to disclose it to another organisation.
8. Protection of personal data
We take reasonable steps to ensure the security of your personal data that is in our possession or under our control and to protect it against risks such as loss or unauthorised access, destruction, use, modification or disclosure. Only authorised personnel are permitted to have access to your personal.
9. Retention of personal data
We stop keeping documents containing your personal data, or we remove the means by which it can be associated with you, as soon as it is reasonable to assume that the purpose for which we collected that personal data is no longer being served by its retention and retention is no longer necessary for legal or business purposes.
10. Complaints procedure
We strive for excellence in providing services to our service users and in all our interactions with donors, and with our employees (which includes our volunteers), as well as with the community generally. This includes our compliance with the PDPA.
Please direct any queries or complaints you have about the way in which we collect, use or disclose your personal data to our Data Protection Officer. Generally, we are unable to deal with anonymous complaints because we are unable to investigate them. If you raise a complaint anonymously, we will nevertheless note the matter raised and, if possible, try and investigate and resolve it appropriately.
Whenever you make a complaint, our Data Protection Officer will seek to obtain sufficient information from you to enable us to investigate it. Please be prepared to provide our Data Protection Officer with information as to, for example:
- the type of action, or lack of action, by us that has given rise to your concern
- whether it was an isolated incident or is ongoing and, in the case of an isolated incident, when it occurred
- a copy of any relevant correspondence you hold, and
- details about what you consider should have happened or should not have happened.
Immediately on receiving your complaint, our Data Protection Officer must investigate it and within 2 business days advise you of:
- the outcome of the investigation and the reasons for that outcome, or
- write to you (which may be by email) advising you that the Data Protection Officer needs more time to investigate the complaint and stating when the Data Protection Officer expects to have resolved the complaint for you.
If a complaint is settled to your complete satisfaction, our Data Protection Officer is not required to advise you in writing of the outcome of the investigation, unless you request a written response (which may be by email).
If a complaint is not settled to your complete satisfaction, our Data Protection Officer will advise you of the outcome of the investigation and the reason(s) for that outcome in writing (which may be by email). If you are not satisfied with the outcome, you may take your complaint to the Personal Data Protection Commission.
11. Data Protection Officer
We have appointed a Data Protection Officer who is contactable as follows:
- send an email to email@example.com.
- call (65) 6664 8588
- write to us at 26 Jalan Klinik, #01-42/52, Singapore 160026
12. Changes to this data protection policy
We may change this data protection policy at any time and from time to time, at our sole discretion, by publishing the latest version on our website. If we make any changes, we will change the “Last Updated” date above.