This Data Protection policy (“policy”) sets out the procedure of how Epworth Community Services (“we, “us” or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act (“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.
Collection, use, disclosure or otherwise processing of personal data of our service users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. Epworth Community Services has appointed a team that will constitute the Data Protection Office to ensure that we will comply with the relevant requirements under the government’s data management policy.
By providing your personal data to us, you agree to the terms of this policy.
1. Collection, Use and Disclosure of Personal Data
In general, we do not collect your personal data unless,
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after,
- you (or your authorised representative) have been notified of the purposes for which the data is collected, and
- you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We will NOT share your personal data with non-Government entities, except where such entities have been authorised to carry out specific Government services. We will not collect your personal data unless the collection and use of your data without consent is permitted or required by the PDPA or other laws. Your personal information will only be collected when necessary and when it has been supplied with consent.
We may collect and use your personal data for any or all of the following purposes:
(a) Performing obligations in the course of or in connection with our provision for the services requested by you;
(b) Verifying your identity;
(c) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) Managing your relationship with us;
(e) Processing donations;
(f) Sending you information about our services, including notifying you of our events and other updates;
(g) Complying with any applicable laws, regulations, codes of practices, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(h) Providing you with information on our upcoming events or activities, where you have specifically requested to receive such information;
(i) Verifying your identity;
(j) Responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
(k) Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(l) Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(m) Any other purposes for which you have provided the information.
We may disclose your personal data:
(a) where such disclosure is required for, or in connection with, the provision of the services requested by you;
(b) to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed above for us;
(c) to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations; and
(d) any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you.
We will not collect, use or disclose your NRICs except in the following specified circumstances:
(a) Required under the law or an exception under the PDPA applies. Where the collection, use or disclosure of NRIC is required under the law or an exception under the PDPA applies. We will notify individuals of the purpose for collection, use or disclosure, as the case may be.
(b) Necessary to accurately establish or verify the identities of the relevant individuals to a high degree of fidelity. Where the collection, use or disclosure of NRIC is necessary to accurately establish or verify the identities of the relevant individuals to a high degree of fidelity.
We should be able to justify upon request by either the regulators or a relevant individual why the collection, use or disclosure of NRIC was necessary to accurately establish or verify the identity of the individual to a high degree of fidelity.
In circumstances where NRICs are not collected, Epworth Community services will be collecting partial NRIC numbers, of only the last 4 digits of the full NRIC.
In the purposes listed the above clauses, a non-disclosure agreement will be handed out to and signed by third party vendors to ensure that personal data is handled with accountability. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us 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 a contract with you).
2. Collection, Use and Disclosure of Personal Data Without Consent
Epworth Community Services may collect, use or disclose your personal data without your consent including but not limited to the following purposes:
(a) It is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(b) The personal data is publicly available;
(c) The collection is necessary for evaluative purposes
(d) The disclosure is for the purpose of contacting the next-of-kin or a friend of any injured, ill or deceased individual.
The purposes listed in the above clause 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.
3. Withdrawal of Consent
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 or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email or otherwise in writing to our Data Protection Officer (DPO) at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require a 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. This includes any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
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 goods or 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 the manner described in the clause above.
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.
4. Access to and Correction of Personal Data
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 via email or otherwise in writing to our DPO at the contact details provided below.
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.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. 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).
5. Data Protection Security
Security of Personal Data is important to us and we take all reasonable precautions to protect Personal Data from misuse, loss, unauthorised access, modification or disclosure.
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 authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, and the use of privacy filters to secure all storage and transmission of personal data by us. Only authorised personnel are permitted to access Epworth’s personal data.
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.
This website may contain links to some sites outside the “epworth.sg” domain whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult the privacy notices of those sites.
6. Accuracy of Personal Data
In general, we 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 DPO in writing or via email at the contact details provided below.
7. Retention of Personal Data
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.
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.
8. Transfers of Personal Data Outside of Singapore
In general, we do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is comparable to that provided under the PDPA.
9. Use of Cookies
In order to improve our website services, we gather information on our website activity by way of “cookies”, where it measures data such as the number of visitors, the pages they visit, the duration of their stay etc. Such information is collected on an aggregate and anonymous basis. The information that we obtain from the use of cookies will not include your personal data unless consent to do so has been provided.
10. Contact Information
You may contact our DPO if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, at .
11. Effect of Policy and Changes to Policy
This policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
Epworth Community Services may revise this policy from time to time without any prior notice or in accordance to updates to the PDPA advisory guidelines. Changes will be reflected in this website and will be notified through email, if applicable and appropriate. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
