JUSTICE WITHOUT BORDERS (JWB) PERSONAL DATA PROTECTION ACT

This Privacy Policy (“Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

This Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us. We may from time to time update this Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

1. Your Personal Data

1.1 In this Policy and under the PDPA, “Personal Data” refers to any data or information (whether true or not) about you from which you can be identified, either (i) from that data; or (ii) from that data and other information to which we have or are likely to have access. Examples of such Personal Data that we may collect include:

  1. Your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, bank account, credit card information and any other information relating to you which you have provided us in any forms that you have submitted to us, or through our other forms of interaction with you;
  2. Information about your use of JWB’s various websites and services, including cookies, IP addresses, policy and claims history information;
  3. Your employment history, educational background and income level; and
  4. Information about your usage of and interaction with our websites and/or services, including computer and connection information including computer and connection information, bandwidth, statistics on page views, and traffic to and from our websites.

2. Collection of Personal Data

2.1 JWB may collect your Personal Data in one or more of the following ways when you:

  1. visit our premises as CCTV recording is on 24 hours a day, 7 days a week;
  2. visit our websites;
  3. donate to JWB;
  4. interact with any of our employees, interns, volunteers, board and committee members e.g. via meetings, emails, workshops or telephone calls;
  5. attend any events hosted by JWB; 
  6. respond to our request for additional Personal Data;
  7. request that we contact you, be included in an email or other mailing list;
  8. respond to our initiatives or programs;
  9. participate in our research and/or survey e.g. via online, face to face or pen and pencil, conducted by us or our partners/vendors;
  10. apply for employment with JWB; 
  11. apply to be a volunteer with JWB; and
  12. apply for an internship with JWB.

Where your Personal Data is given to us from third party social networking services when you choose to connect with those services.

2.2 When you browse our websites, you generally do so anonymously, but please see Section 10 below which provides more information on our cookie policy.

2.3 You shall consult your parent or guardian before providing us with your Personal Data if you are under the age of thirteen [13].

2.4 Accuracy: JWB will make reasonable efforts to ensure that the Personal Data we collect is accurate and complete. Please help JWB by ensuring that all Personal Data that you submit is complete and accurate. You may update us when there are any changes to the Personal Data which you have provided to us by emailing us via the email address set out in paragraph 13 below. We will correct or complete your Personal Data as soon as reasonably practicable.

3. Purposes for the Collection, Use, and Disclosure of Your Personal Data

3.1 JWB may collect, use and/or disclose your Personal Data for the purposes for which we have specifically obtained your consent and for the purposes for which you have provided your Personal Data to us. Some of the purposes are listed below:

  1. Assessing and processing any applications made by you for services offered by JWB;
  2. Preparation of the relevant document(s) for the services used by you;
  3. Facilitating the verification and checks of your Personal Data in order to provide you with our services which you have requested;
  4. Communicating with you to inform you of changes and updates to our services, policies, terms and conditions and other administrative information, including without limitation for the purposes of servicing you in relation to services offered to you;
  5. Administering, maintaining, managing and operating the services offered to you;
  6. Processing payment, billing, account, credit checks and debt-recovery matters;
  7. Processing and administering benefits or entitlements (if any) in connection with your employment, internship or volunteering with JWB;
  8. Responding to your queries and requests, including to handle any complaints;
  9. Conducting research and surveys; 
  10. Managing our infrastructure and business operations and complying with internal policies and procedures;
  11. Processing donations to JWB and/or other Voluntary Welfare Organisations (VWOs);
  12. Processing employment, internships and volunteering opportunities with JWB;
  13. Sending you our upcoming services and updates; 
  14. Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities and agencies; and/or
  15. Any other purposes set out in this Policy.

3.2 You warrant and represent to us that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with services you have requested and/or to process the necessary administration.

3.3 JWB will seek your prior consent for any disclosure of your Personal Data in relation to these purposes and for any other purpose that is not listed above.

3.4 Where Personal Data is submitted by you on behalf of another individual or concerns another individual other than yourself (or, in the case of situations where you, as a representative of your company or organisation are submitting the personal data of individuals as part of the disclosures by the company or organisation to us), you warrant and represent to us, that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.

3.5 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving upcoming events and updates from JWB via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s), including via voice calls, text, fax or other means to provide you with our updates.

4. Disclosure of Personal Data

4.1 Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, may be disclosed for the purposes listed above, where applicable, to the following parties:

  1. Our employees, volunteers, interns, board and committee members;
  2. Third party service providers who provide services such as courier services, payroll, mailing, information technology, data processing, insurance services to JWB;
  3. Any liquidator, receiver, official assignee/trustee, judicial manager or any other person appointed under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other analogous process in respect of any individual, company or business;
  4. Our professional advisers such as our auditor(s) and lawyer(s);
  5. Any judicial, administrative or regulatory body, any public or government agency, or any parties thereof having jurisdiction over JWB;
  6. Any other party to whom you authorise us to disclose your Personal Data to; and/or
  7. Other purposes reasonably incidental to the above when dealing with parties to whom disclosures have been made.

5. Transfer of Personal Data outside Singapore

5.1 Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. 

5.2 This will include obtaining consent from you to transfer your personal data overseas, and before you give consent, providing you with a reasonable written summary on the extent of the protection offered to the personal data to be transferred overseas, and/or taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the standard of protection under Singapore’s PDPA.

6. Withdrawal of Consent

6.1 If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may contact the relevant JWB Data Protection Officer (DPO). The DPO’s contact information is located in Section 13 (Contacting Us).

6.2 Please note that if you withdraw your consent to the collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be able to continue providing our services or performing our contractual obligations to you. Such withdrawal may also result in the termination of any agreements or arrangements you may have with us. JWB’s legal rights and remedies are expressly reserved in such an event.

7. Access and Correction of your Personal Data

7.1 You may request access to or make corrections to your Personal Data records that JWB has. Please submit your request to JWB’s Data Protection Officer (DPO) identifying yourself and indicating the Personal Data that the request concerns. For the DPO’s details, refer to Section 13 (Contacting Us).

7.2 JWB will strive to respond to each request for access or correction as soon as reasonably possible or as soon as practicable, and as accurately and completely as necessary. However, please note that we may refuse your request under certain circumstances as laid out under the PDPA. We may also charge you a reasonable administrative fee for the handling and processing of your request to access your personal data. We will provide you with a written estimate of the fee we will be charging.

7.3 Our response time to your request is within 30 days from receipt of your request. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. If more than 30 days are required, we will inform you within the first 30 days of the time when we would be able to respond to your request.

8. Protection, Policies and Procedures

8.1 We will endeavor to protect your Personal Data in our possession or contract against risks of unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures.

8.2 We strive to ensure that our systems are reasonably secure and that they meet industry standards.

8.3 To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect.

8.4 Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.

9. Retention of your Personal Data

9.1 We will retain your Personal Data for a reasonable period for which the Personal Data being collected is serving the purpose for which the individual has been notified and has consented to. Also, Personal Data may be retained for as long as necessarily required or relevant for business or legal purposes.

10. NRIC and other National Identification Numbers

10.1 We may collect, use, or disclose NRIC numbers (or copies of NRIC), Birth Certificate numbers, Foreign Identification Numbers, Work Permit numbers, and/or other national identification numbers without your consent when it is required under the law, or when an exception under the PDPA applies.

10.2 We may also collect, use, or disclose NRIC numbers (or copies of NRIC), Birth Certificate numbers, Foreign Identification Numbers, Work Permit numbers, and/or other national identification numbers when it is necessary to accurately establish or verify the identities of the individuals to a high degree of fidelity. Examples of such situations include those where a failure to accurately identify the individual to a high degree of fidelity may pose a significant safety or security risk, or a risk of significant impact or harm to an individual and/or JWB (e.g. fraudulent claims). Such transactions typically relate to healthcare, financial or real estate matters, such as property transactions, insurance applications and claims, applications and disbursements of substantial financial aid, background credit checks with credit bureau, and medical check-ups and reports.

11. Use of Cookies

11.1 We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points of our websites.

11.2 We use “cookies” where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our website. The cookie is used to track information such as the number of users, their frequency of use, profiles of users, and their preferred sites.

11.3 The Aggregate Information collected is used to assist us in analysing the usage of our websites and improving our websites.

11.4 Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings in your browser. However, if you do so, you may not be able to enter certain part(s) of our websites.

12. Third Party Sites

12.1 Our websites may contain links to other websites operated by third parties for your convenience and information.  You access these websites at your own risk. To the fullest extent permitted under law, we cannot be responsible for a third-party’s acts, omissions, data policies or their use of cookies nor the content or security of any third-party websites, even if linked to our websites.  We recommend that you check the applicable data protection policy of the third party to determine how they will handle any information they collect from you. Any such liability is expressly disclaimed and excluded.

13. Contacting Us

13.1 If you have any questions, feedback or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our JWB Data Protection Officers (DPOs) at info@forjusticewithoutborders.com.

14. Updates on Privacy Policy

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. 

We reserve the right to amend the terms of this Policy at our absolute discretion. Any amended Policy will be posted on our website and can be viewed at https://forjusticewithoutborders.org/.

Last updated on 16 June 2020.