[Last updated on 17 Mar 2022]
1. Overview and Scope
Your personal data privacy is important to SG Enable Ltd (“SG Enable”) and we are highly committed in respecting and managing your Personal Data collected in line with this Policy.
2. When and what kind of Personal Data does SG Enable collect?
SG Enable may collect, use and disclose the following data about you in the circumstances as set out below:
- When you provide Personal Data by filling in online or hardcopy forms to apply for SG Enable’s various services, schemes, projects and initiatives (either as a beneficiary or as a caregiver) or providing feedback, asking queries and other submissions;
- If and when you contact SG Enable (e.g. telephone calls, text messages, online chat programmes, Sites, emails, face-to-face meetings), we may keep a record of that correspondence;
- Details of your visits to SG Enable’s Sites, including, but not limited to, cookies, location data and other communication data, that you access;
- When you fill in online or hardcopy forms to apply for a job or internship at SG Enable;
- When you register to be a volunteer or donor for the various projects, programmes and initiatives at SG Enable;
- When you are referred to SG Enable by a government agency, other partners and social service agencies (“SSA”);
- When you participate in surveys, events, awards, promotions, competitions, contests, or other activities conducted or organised by SG Enable;
SG Enable may collect the following kinds of Personal Data or such other kinds through the different and other possible channels other than those mentioned above:
1. Full name;
5. Marital Status;
6. Date of Birth;
7. Residential addresses;
8. Personal email addresses;
9. Mobile and telephone numbers;
10. Photos and videos (including CCTV), if applicable;
11. NRIC/WP/FIN/Passport numbers and copies, when needed; and
12. Bank account details;
13. Educational history, qualifications, training and education transcripts (including NS certificates);
14. Next of Kin, family and emergency contact information;
15. Medical and insurance information (including doctors’ letters, memos and reports to demonstrate proof of disability);
16. Employment history and professional qualifications, including testimonials and information disclosed about references and payslip from previous employers, if necessary;
17. Legal and financial history; and
18. Curricula Vitae, if any;
3. For what purposes does SG Enable collect, use and disclose Personal Data?
SG Enable may use or disclose the personal data we collect from you for any of the following purposes:
To carry out contractual obligations and administer services and programmes
- To carry out SG Enable’s obligations arising from any contracts entered into between you and us or on behalf of government ministries and agencies. This includes notifying you of the status of services or schemes you have requested, assessing your eligibility for services and schemes and providing you with the services or schemes that you have applied or requested (for which we may share your personal data with relevant third parties such as government ministries and agencies, training partners, other SSAs and our other partners;
- To enable SG Enable’s officers and employees, related entities, service providers, vendors, advisors, subcontractors and third-party partners and agents (e.g. government ministries and agencies, training partners, and other SSAs, etc.), to fulfil the obligations/ services as stipulated in your contract with SG Enable;
- To respond to service or scheme requests and enquiries;
- To facilitate referrals to other agencies that may provide relevant services, schemes or assistance to you;
- For fund-raising administration and management purposes;
- For payment administration and management purposes, including evaluation of suitability for application of subsidies and grants, disbursement of prize monies, etc.;
- To facilitate the planning, delivery, maintenance and enhancement of SG Enable’s services and offerings;
- To provide training and education, including events and seminars;
For relationship management and communications
- For beneficiary, donor, caregiver, volunteer, and any other third-party relationship management and administration purposes, including maintaining a record of your previous transactions with us;
- To inform you about SG Enable’s schemes, services, programmes, courses, events, or other information that may be relevant to you.
- For marketing and publicity efforts by SG Enable and or our partners if you have provided consent for such purposes;
- To produce materials for training, internal and/or external communications, publicity, or other purposes deemed appropriate by SG Enable whether in the print, online or in any other media including but not limited to photographs, images, audio or video files, with your consent.
- For tenant, potential employer, vendor and partner management and communications purposes;
For Human resource management purposes
- For recruitment and evaluation purposes if you apply for a job, internship, or volunteering opportunity as well as other similar undertakings with SG Enable, e.g. to determine your suitability;
- To apply for employee work passes at the Ministry of Manpower, if needed;
Other business and legal purposes
- Complying with legal and regulatory obligations and requirements;
- To facilitate research, data analysis, and business planning purposes;
- To process your enquiries and other ancillary administrative purposes;
- For security, identity verification and safety surveillance and monitoring purposes, including but not limited to, contact tracing;
- For internal approval and reporting, accounting, audit, compliance, and record-keeping purposes;
- To provide your personal data to industry regulators and other government organisations, as required by local laws and regulations; financial institutions, for purposes such as facilitating payments, screenings or checks; as well as organisations, for the purposes of research, data analysis, evaluation and policy formulation, for which you will not be identified as a specific individual.
- Purposes incidental to each or all of the above or such other necessary purposes.
We may also contact you by any means of communication for which you have provided your contact details, including but not limited to email, telephone, face-to-face meetings, SG Enable’s Sitessgenable.sg.
4. Consent for the collection and use of your Personal Data and Accuracy of Personal Data collected
Please note that if you do not consent to any of the above business purposes, SG Enable may not be able to meet the purposes for which the information was collected.
5. Does SG Enable disclose or transfer Personal Data to third parties?
On occasions, SG Enable may use third-party partners and agents (e.g. government ministries and agencies, training partners, other SSAs, etc.), to assist us in the use (which includes processing) of your Personal Data as outlined under “For what purposes does SG Enable collect, use and disclose Personal Data?” You consent to such use of your Personal Data by continuing to browse SG Enable’s Sites, or to engage with SG Enable.
In the course of providing our services, SG Enable may transfer Personal Data outside Singapore. If Personal Data is transferred, SG Enable will accord the Personal Data a level of protection, which is comparable to the protection accorded under Singapore’s Personal Data Protection Act 2012 (“PDPA”).
6. For how long does SG Enable retain your Personal Data?
SG Enable will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes
SG Enable may collect personal data via technologies used on our Sites and web-based applications to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on our behalf. Such data does not generally, but may, contain a user’s personal data. Examples of such technologies include:
i. Click-stream data.A visit to one of our Sites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data may include, but is not limited to, the following:
- the visitor’s IP address
- the date and time of the visit
- the referral URL (the site from which the visitor has come)
- the pages visited on our Sites
- information about the browser used (browser type and version, operating system, etc)
iii. Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to users. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our Sites. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received, opened, and responded to.
iv. Web analytics. Web analytics is the term given to a method of collecting and assessing the behaviour of visitors to websites and mobile applications. This includes the analysis of traffic patterns, for example, to determine the frequency of visits to certain parts of a website or mobile application or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more about the processing of web analytics data in paragraph 12.
8. How does SG Enable protect your Personal Data?
SG Enable implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be protected, SG Enable cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
Your Personal Data will only be expressly used for SG Enable’s purposes as listed in clause 3, and shall not be sold or disclosed to any other third party for any other purposes whatsoever without your consent.
9. Links to third party Sites from SG Enable’s website
Our Sites may contain links to external sites, such as those of our business partners. Some of these sites may feature our logo or trademark. However, these sites are neither owned nor maintained by us and we are not responsible for the privacy policies and practices of these Sites. Please contact the owner of the respective Sites should you have questions on their privacy policies.
10. Use of plug-ins from Social Networks
SG Enable’s Sites and web-based applications may provide you with social plug-ins from various social networks (e.g. Facebook, LinkedIn, Instagram). If you interact with such social networks, your activity on our Sites or via our web-based applications will be made available to these networks.
If you do not wish for such a data transfer, please log off on your social network before entering our Sites or web-based applications.
We cannot influence data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for details about their collection and transfer of personal data, and how you can achieve satisfactory privacy settings.
11. Geo-location Services
SG Enable’s sites, mobile and web-based applications may offer location-enabled services, such as Google Maps and Bing Maps. If you use such applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You are always asked if the geo-location service can be activated and you can disallow the geo-location service within the application.
12. Web analytics
SG Enable’s Sites, mobile and web-based applications may contain web analytic services provided by Google Analytics, Facebook Pixels or such third parties from time to time. When you visit or use our Sites or any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings disallow such cookies. Personal data collected will be sent to Google Analytics, Facebook Pixels or such third parties for analysis for and on behalf of us.
Google Analytics, Facebook Pixels or these third parties act only as our agent and we determine the purposes for which the data is being used and which will be consistent with purposes and provisions stated herein. You can find out more about the relationships between Google Analytics, Facebook Pixels or these third parties and us in their respective privacy policies.
If you do not wish for information about your behaviour at our sites or web-based applications to be collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
SG Enable may use Facebook’s tracking pixels and “Custom Audiences” on our Sites and web-based applications. Clicks on Facebook ads that redirect you to our Sites and web-based applications, can be tracked to assess the effectiveness of Facebook ads. Such data is stored by Facebook, which may also use the data for its promotional purposes, in accordance with its Data Policy. You may update your ad settings on Facebook by following the instructions at https://www.facebook.com/adpreferences/advertisers/?entry_product=ad_preferences_delegation to control the advertisements being shown to you.
13. Retargeting Technologies
SG Enable’s Sites and web-based applications may use retargeting technologies within the internet to show our visitors, who were already interested in our services, information from us on partner Sites.
We also work with companies which use tracking technologies to deliver information for us across the Internet.
Retargeting technologies analyse your cookies and display information based on your past surfing behaviour. For further information on cookies, please refer to Clause 7 of this Policy.
We do not store any personal data about you with this technology.
14. Requests for Access and Correction and Withdrawal of Consent of Personal Data, Feedback and Queries
Please contact us at PDPA@sgenable.sg if you have any queries or feedback regarding your Personal Data or this policy. If you wish to access or correct your Personal Data, please identify yourself clearly and state which Personal Data and information about its use and/or disclosure is requested.
We will respond to your request as soon as reasonably possible. If we are unable to respond to your request within thirty (30) days, we will inform you in writing as to when we can respond. If we are unable to provide or correct any personal data as requested by you, we shall generally inform you of the reasons (except where we are not required to do so under the PDPA).
15. Further Information
SG Enable reserves the right to change this Policy with or without notice from time to time.
16. Governing Law
This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.