PACLIN’s Data Protection Policies-
At PACLIN, Singapore, we take our responsibilities under Singapore’s Personal Data Protection Act 2012 (PDPA) seriously. We also recognise the importance of personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This data protection policy applies to PACLIN OFFICE PRODUCTS PTE LTD established in Singapore (“Paclin”). This policy is designed to assist you in understanding how we govern the collection, use and disclosure of personal data submitted to PACLIN, which includes through our website paclin.com.sg. We also explain how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA"). In this policy, “personal data" shall have the meaning ascribed to it in the PDPA.
If you, at any time, have any queries on this policy or any other queries in relation to how we manage, protect and /or process to our Data Protection Officer at +(65) 67429255
1. Introduction to PDPA
1.1 “Personal Data" is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2. Purposes for Collection, Use, Disclosure and Processing of Personal Data
2.1 Main Data Protection Policy
We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact. We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.
Personal data which we collect from you may be collected, used, disclosed and/or processed for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified.
2.2 Privacy on our Websites
This policy applies to any personal data collected via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that and may be used on some pages of our websites to assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from their system if they wish.
2.3 Recruitment Data Protection Policy
As part of our recruitment process, we collect necessary personal data for employment with our firm. During the course of the recruitment and selection process, we may request for further information to assess the suitability for positions with our firm. In doing so, we only collect personal data that is necessary for recruitments decisions. The procedures used by the firm to gather further information to include:
(a) Selection interviews
(b) Assessment centres
(c) Written skills tests
(d) Referee reports
(e) Security Vetting
(f) Necessary pre-employment activities
References from your current or former employer(s) or other sources will only be obtained with your consent. In some cases, pre-employment checking may be necessary. Any checking is “tailored” and the extent and nature of information sought is no more than is justified the processing and outcome of your application.
2.4 We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with the following:
(a) To provide you with our products/ services, the entry into and/or performance of any transactions with us, and the facilitation of any of the following;
(b) To respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection;
(c) To maintain contact with clients and other contacts;
(d) To keep clients and other contacts informed of the services we offer, industry developments, service offerings, and other events we are holding, that may be of
interest to them
(e) Processing and/or storing information related to your relationship with us;
(f) For general management and report purposes, such as invoicing and account management
(g) For recruitment purposes and purposes related to the employment of our personnel,and providing service to our personnel
(h) Monitor and record telephone conversations, voice or video conferences and all electronic communications for record keeping, quality training and investigation
(i) Complying with applicable law, regulations, guidelines and/or notices in administering and managing your relationship with us; and/or any other purposes which we may notify you of at the time of obtaining your consent, (collectively, the “Purposes")
(j) Managing our infrastructure and business operations, and complying with policies and procedures that may be required by law, applicable regulation, guidelines or notices and/or that may have been put in place by us, including those relating to regulatory review and/or oversight, auditing (whether internal or external), finance and accounting, billing and collections, IT systems, data and website hosting, training, testing, business continuity, and records, document and print management;
(k) All other purposes related to our business. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law. For more information on the exceptions, you are encouraged to peruse Second and Third Schedules of the PDPA which are publicly available at http://statutes.agc.gov.sg.
3. Specific Issues for the Disclosure of Personal Data to Third Parties
3.1 We will respect the confidentiality of the personal data provided to us
3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situation, including, without limitation, the following:
(a) Cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) Cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) Cases in which the disclosure is necessary to respond to an emergency that threatens the lift, health or safety of yourself or another individual;
(d) Cases in which the disclosure is necessary for any investigation or proceedings;
(e) Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) Cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) Where such disclosure without your consent is permitted by the PDPA or by law.
3.3 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data
3.4 If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
4. Disclosure of Personal Data to Third Parties
4.1 You represent, undertake and warrant to us that:
(a) In respect of any personal data of any individuals whatsoever which you may, from time to time, disclose to us (“Third Party Personal Data”), you would have prior to disclosing such Third Party Personal Data to us obtained the appropriate consent from the individuals whose Third Party Personal Data are being disclosed, to:
(i) Permit you to disclose the individuals’ Third Party Personal Data to us for or in connection with the Purposes; and/or
(ii) permit us and our affiliates or related corporations (in Singapore and/or elsewhere) to collect, use, disclose, share and/or process (through authorised service providers, relevant third parties or otherwise) the individuals’ Third Party Personal Data for or in connection with the Purposes;
(b) Any Third Party Personal Data that you disclose to us are accurate;
(c) Should you become aware that any such Third Party Personal Data has been updated and/or changed after such disclosure to us, you shall give us notice in writing as soon as reasonably practicable thereafter; and
(d) Should you become aware that any individual whose Third Party Personal Data you have disclosed to us has withdrawn his consent as referred to in sub-clause (a) above, you shall give us notice in writing as soon as reasonably practicable thereafter.Without prejudice to our other rights under law and/or the agreements (s) between you and us, upon our receipt of the said notification, we shall have the right to discontinue or not provide any products and/or services and/or transactions with you that are linked to such Third Party Personal Data.
4.2 If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
4.3 Any individual may choose to unsubscribe or elect not to receive further marketing information from us by contacting our Data Protection Officer, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 28 days.
4.4 We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
4.5 We may disclose personal data to other members of the PACLIN firm, where it is necessary (i) to meet the purpose for which such individual has submitted the
information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests. We may also transfer all data in our possession to a successor-in-interest to our business or assets.
5. Access to and Correction of Personal Data
5.1 Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA, by contacting us using the hotlines provided in this policy.
5.2 Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
5.3 We reserve the right to charge a fee for handling and processing your requests to access and/or correct your personal data. Such fee will depend on the nature and complexity of your request in line with the requirements of PDPA
5.4 Upon reasonable notice given for the withdrawing of your consent to our collection, use or disclosure of your Personal Data in Whole or in part, depending on the nature and scope of your withdrawal of consent, we will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws. We shall also have the right to discontinue or not provide any products and/or services to and/or transactions with you that are linked to such Personal Data.
6. Administration and Management of Personal Data
6.1 Accuracy of Personal Data
We will make reasonable efforts to ensure that personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you or is disclosed to another organisation. However, this means that you must also update us of any changes in your personal data from time to time. We will not be responsible for replying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data from time to time in a timely manner.
6.2 Security and Protection of Personal data
We will put in place generally accepted standards of security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alternation of your personal data. Only authorised PACLIN personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control
6.3 Retention of Personal Data
We will put in place measures that will cease to retain personal data, as soon as it is reasonable to assume that (i) the purpose for collection of such personal data is no longer being served by such retention, and (ii) retention is no longer necessary for legal or business purposes.
7. Updates on Data Protection Policy
7.1 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 Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.For more information about the data protection notice, please click here