Public Speaking Academy – Personal Data Protection Notice
The Public Speaking Academy Pte Ltd (“PSA”) is committed to ensuring the protection and respect of the privacy of our students/clients. We recognise the need for careful and open management of your personal data as part of your trust in us. In line with this, this Personal Data Protection Notice (“Notice”) sets out the basis upon which PSA may collect, use, disclose or otherwise process personal data of our students/clients in accordance with the Personal Data Protection Act (“PDPA”) (you can find out more about the obligations under the PDPA through their guide here.
This Notice is to assist you in understanding how PSA maintains the protection and respect of the 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. We have developed this Notice to help you understand how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
We encourage an open, frank, and amicable platform – if you have any concerns about the collection, use, and/or disclosure of your personal data with PSA, please reach out to our Data Protection Officer through email@example.com.
DEFINITIONS & TERMS
- This section sets out the the definitions of key terms as used in this Notice:
“students/client(s)” means an individual or individuals who (a) has/have contacted PSA through any means to find out more about any goods or services we provide, (b) may, or has/have, entered into a contract with PSA for the supply of any goods or services by us, or (c) has/have signed-up, enrolled or is attending any courses, lessons, assessments, examinations or any other programmes/events with PSA, on behalf of themselves or others; and
“personal data” means data, whether true or not, about a student/client 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.
- What type of personal data do we collect? Depending on the nature of your interaction with PSA, some examples of personal data which we may collect from you include, but are not limited to, name, 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.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE, AND PROCESSING OF PERSONAL DATA
- Collection of personal data: PSA generally does not collect your personal data unless
- it is provided to PSA 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 (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, used, and/or disclosed and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
- collection, use or disclosure of personal data without consent is permitted or required by the PDPA or other laws.
- PSA 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 e.g. when the personal data is publicly available).
- When will we collect personal data from you? Generally, we collect your personal data when you, among others:
- register, enrol or sign up for any courses, lessons, assessments, examinations or any other programmes conducted, operated and/or managed by PSA (which include requests to be placed on any wait-lists), whether as a student yourself or through parents registering for their children;
- express an interest or request for more information on any courses, lessons, assessments, examinations or any other programmes conducted, operated and/or managed by PSA; or
- visit our website or other online/social media platforms, and leave behind your contact information.
- How do we use your personal data? PSA may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services offered by PSA, and requested by you;
- sending you updates and/or managing the administrative aspects about the courses, lessons, assessments, examinations or any other programmes conducted, operated and/or managed by PSA, and to allow PSA to provide these services to you;
- verifying your identity in facilitating the administration, management or conduct of the courses, lessons, assessments, examinations or any other programmes by PSA;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you pertaining to the courses, lessons, assessments, examinations or any other programmes by PSA;
- administering and/or managing your relationship with us (including, but not limited to, responding to enquiries, the mailing of correspondence, statements or notices which could involve the disclosure of certain personal data to bring about delivery of the same);
- processing payment or credit transactions;
- 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;
- any other purposes for which you have provided the information;
- 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
- any other incidental business purposes related to or in connection with the above.
- When will we disclose your personal data? PSA may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you (e.g. such as security clearance for a specific training venue where required);
- to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us;
- where required to do so by law i.e. we may disclose personal data about you to the relevant authorities or to law enforcement agencies where required.
- 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 a contract with you).
WITHDRAWAL OF YOUR 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 in writing. You may withdraw consent and request PSA to stop collecting, 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 PSA at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, PSA may require reasonable time (depending on the complexity of the request, its impact on our relationship with you, or the conduct of any courses, lessons, assessments, examinations or any other programmes) 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 fifteen (15) 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. For example, without your personal data, we are unable to arrange any relevant training programme for you or your child. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 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.
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 in writing or via email to PSA at the contact details provided below.
- Please note that a reasonable fee (for the handling and processing of your request) may be charged for an access request. If so, we will inform you of the fee before processing your request.
- PSA will respond to your written 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).
- If, for any reason whatsoever, you are uncomfortable with the manner or extent of collection, use and/or disclosure of your personal data by PSA, we encourage you to inform us through our contact point below so that a reasonable and mutually acceptable solution to your concerns can be found.
PROTECTION OF PERSONAL DATA
- 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, and disclosing personal data to authorised persons only on a need-to-know basis.
- 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, PSA strives to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- If a data breach occurs (e.g. personal data held by us is lost, stolen, inadvertently disclosed to an external party, or accidentally published), our team will assess the nature of the breach to determine if it is notifiable breach (as per the Data Breach Notification obligation under the PDPA). We will notify you within a reasonable timeframe should such a breach occur. Our team reiterates our commitment in maintaining an open, amicable, and expeditious channel in ensuring the protection of your personal data.
ACCURACY OF PERSONAL DATA
- PSA generally relies on personal data provided by you (or your authorised representative) in the provision and conduct of our services (such as PSA’s courses, programmes or lessons). 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 PSA in writing or via email at the contact details provided below (such as a change in your contact number or email address).
RETENTION OF PERSONAL DATA
- PSA 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.
- PSA 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
- PSA generally does 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 at least comparable to that provided under the PDPA.
CONTACT POINT & DATA PROTECTION OFFICER
- You may contact firstname.lastname@example.org if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice 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 PSA.
- We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
|Effective Date||18 Jan 2020||Last Amended:||29 Sep 2021|