Data Protection Notice

Data Protection Notice

This Data Protection Notice (“Notice”) sets out the basis on which Club HEAL (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of prospective service users, service users, service users’ authorised representatives, donors, volunteers, visitors, job applicants, employees, board members or otherwise in accordance with the Personal Data Protection Act (“PDPA”). This Notice 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.

We may collect, use, and disclose personal data on behalf of government ministries, statutory boards, or public agencies in Singapore. In such cases, we will comply with the data protection policies and frameworks prescribed by the relevant authorities, including the Government Instruction Manual on IT Management (IM8) and other applicable guidelines.

PERSONAL DATA

As used in this Notice:

“service user, donor, volunteer, authorised representative, visitor, job applicant, employee, or board member” means an individual who:

(a) has contacted us through any means to find out more about any goods or services we provide

(b) may, or has, entered into a contract with us for the supply of any goods or services by us

(c) has entered our premises for meetings, interviews, visits, tours, events, employment, volunteering, or board-related activities

(d) has engaged with us in the capacity of a Board or Committee Member, or

(e) has otherwise engaged with Club HEAL

“personal data” means data, whether true or not, about an individual (whether a prospective service user, service user, service user’s authorised representative, donor, volunteer, visitor, job applicant, employee, board member, or otherwise) 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

Depending on the nature of your interaction with us, some examples of personal data that we may collect from you include your name, NRIC, FIN, work permit, birth certificate, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, medical history, employment information, financial information, declarations, qualifications, and audio-visual data.

If you provide us with any personal data relating to a third‑party individual (such as referees, next‑of‑kin, emergency contact persons, caregivers, or authorised representatives), you confirm that you have obtained that individual’s consent to disclose their personal data to us for the purposes described in this Notice.

Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally 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

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorised representative) have provided written consent to the collection and use 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 that has not been notified to you (except where permitted or authorised by law).

You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in the “WITHDRAWING YOUR CONSENT” section below. However, please note that we may not be able to continue with your job application, employment, services, volunteer engagement, board appointment or other interactions with us in the absence of the required personal data.

We may collect and use your personal data for any or all of the following purposes of establishing or managing your relationship with us. This includes:

Where you are a prospective service user:

processing and evaluating your application for our services

Where you are a service user:

providing the services requested by you
monitoring, evaluating and/or auditing the services provided. This may include assessing the quality of the services provided and the effects of the services provided (both in the short and long term, and after you have stopped using the services)
research related to your personal circumstances or services you have used. We will notify you and obtain your written consent before using your personal data for any specific research project, unless otherwise permitted under the PDPA or other legislation

Where you are a service user’s authorised representative:

processing and evaluating the service user’s application for our services

Where you are a donor:

processing your donations and your tax-deduction claims

Where you are a volunteer:

processing and evaluating your suitability to volunteer
monitoring, evaluating and/or auditing the services you participated in

Where you are a visitor,

managing and recording your entry into our premises
ensuring safety and security, including CCTV monitoring
complying with statutory requirements such as health-related directives
facilitating participation in visits, tours, events or meetings

Where you are a job applicant,

processing and evaluating your job application
contacting you regarding interviews or assessments
verifying information you have provided
facilitating pre-employment checks

Where you are an employee,

performing obligations under or in connection with your employment with us
administering payroll, benefits, leave, insurance, and training
granting access to premises and systems
managing the employment relationship
ensuring workplace safety and operational requirements
assessing suitability for continued employment or appointments

Where you are a board member (including prospective board directors),

processing and evaluating your suitability for appointment
managing board and committee appointments and cessations
coordinating board and committee meetings
performing statutory and regulatory filings (e.g., ACRA, COC)
maintaining governance administration and secure board communications
complying with legal, regulatory, and corporate governance requirements
facilitating duties and responsibilities relating to your board role

We may also collect, use, and/or disclose your personal data for:

providing you with information on our upcoming events or activities (where requested);
verifying your identity
responding to, handling, and processing queries, requests, applications, complaints and feedback
complying with applicable laws, regulations, codes of practice, guidelines, rules, or assisting in law enforcement
any purposes for which you have provided the information
transmitting personal data to third‑party service providers, agents, or authorities
any other incidental purposes related to or in connection with the above

The purposes listed above may continue to apply even if 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, such period as may be necessary to enable us to enforce our rights under a contract with you).

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Club HEAL or another person. In relying on the legitimate interests’ exception under the PDPA, Club HEAL will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

Fraud detection and prevention
Detection and prevention of misuse of services
Network analysis to prevent fraud and financial crime, and perform credit analysis
Collection and use of personal data on company-issued devices to prevent data loss

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until it is withdrawn by you in writing. Should you decide to cancel your withdrawal of consent, please inform us in writing to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require 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 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 ten (10) business days of receiving it.

While 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.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use or disclosure 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 to our Data Protection Officer 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 fourteen (14) business days. If we are unable to respond within thirty (30) days of receiving your request, we will inform you in writing. If we are unable to provide you with the requested personal data or make the requested correction, we will inform you of the reasons, except where we are not required to do so under the PDPA.

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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-know access for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating systems and other software, secure erasure of storage media in devices before disposal, web security measures against risks, usage of one-time passwords (OTP), two-factor authentication (2FA) or multi-factor authentication (MFA) to secure access, and security review and testing performed regularly.

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.

ACCURACY OF PERSONAL DATA

We generally 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 Data Protection Officer in writing at the contact details provided below.

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.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data outside Singapore. However, if we do so, we will obtain your consent, where required for the transfer, and 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.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures or if you wish to make any request, in the following manner:

Contact No: 6899 3463

Email Address: dpo@clubheal.org.sg

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 us.

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.