Personal Data Protection Policy
This Personal Data Protection Policy (“Policy”) applies to [Asia Green Grid Network – insert correct company name here once we have it] (“Asia Green Grid Network”, “AGGN, “we”, “us” or “our”). It seeks to inform you of how we may collect, use, disclose or otherwise process Personal Data in accordance with the Personal Data Protection Act in Singapore (“PDPA”). This Policy 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.
By submitting information to us, engaging our services, or otherwise interacting with us, you agree and consent to us collecting, using and disclosing your Personal Data in accordance with the terms of this Policy. Your consent, pursuant to this Policy or otherwise, is in addition to any other rights which we may have at law to collect, use and disclose your Personal Data.
Personal data
1. In this policy “Personal Data” means data, whether true or not, about a person who can be identified:
(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC 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, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure of personal data
4. We may collect Personal Data in various ways including:
(a) in the course of your engaging our services, or your providing documentation or information to us;
(b) when you communicate or interact with us via telephone calls (which may be recorded), letters, fax, face-to-face meetings, our websites, email or other modes of contact;
(c) when you visit our website;
(d) when you contact us or request that we contact you;
(e) when you respond to our request for additional Personal Data;
(f) when you respond to our initiatives or surveys;
(g) when you participate in events organised by us;
(h) when you request that you be included in an email or other mailing list, alerts or newsletters; and
(i) when you submit your Personal Data to us for any other reason.
We may also use “cookies” on our website. A “cookie” is a small amount of data transferred to your browser and read by the web server that placed it there. It works as a sort of identification card, recording your preferences and previously entered information. By using cookies, the information you previously provided can be retrieved on your next visit to the website so that your navigation time is reduced and your use of the website is simplified. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie. Web beacons may be used to deliver the cookie and to compile the statistics about our website, such as how many people visited a particular page or clicked on certain links.
Portions of our website may use cookies to help ensure the integrity of any registration process or to help provide personalised service and deliver content specific to your interests. You can set your browser to decline cookies if you prefer. If you do so, you may not be able to get the benefit of some of the features of our website that you visit.
5. 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 services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 4 above for us.
6. 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).
Withdrawing your consent
7. 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.
8. 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 ten (10) business days of receiving it.
9. 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 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 7 above.
10. 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.
Access to and correction of personal data
11. 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.
12. 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.
13. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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 (except where we are not required to do so under the PDPA).
Protection of personal data
14. 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 such as up-to-date antivirus protection, encryption and the use of privacy filters 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.
15. 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.
Accuracy of personal data
16. 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.
Retention of personal data
17. 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.
18. 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.
Transfers of personal data outside of Singapore
19. Your personal data may be transmitted outside of Singapore to Australia. In such a case it will be subject to the comparable Australian Act – The Privacy Act 1988 (Privacy Act).
Data protection officer
20. 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:
[details of data protection officer email here]
Effect of policy and changes to policy
21. This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
22. We may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.