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The Centre for International Education Data Protection Policy

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Background

The Singapore Personal Data Protection Act – 2012 (PDPA) establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

The PDPA takes into account the following concepts:

  • Consent – organisations may collect, use or disclose personal data only with the individual’s knowledge and consent (with some exceptions) 

  • Purpose – organisations may collect, use or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use or disclosure 

  • Reasonableness – organisations may collect, use or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances 


Consent

It is reasonable and accepted that parental consent is sufficient for students in grades up to and including Grade 8.

Each adult must provide individual consent. The consent may be given as a separate form or as part of the general terms and conditions of enrollment.

Implied consent

Where a person has made a free decision to opt in to a process or situation where the collection or use of personal data can be reasonably expected, then implied permission can be assumed, but should still be highlighted. This is the case with events run at the Centre for International Education.

Policy

The Centre collects and uses personal data about delegates and anyone who registers delegates in accordance with the Singapore Personal Data Protection Act - 2012 (PDPA) and other relevant laws and requirements on private education institutions in Singapore.

Data Collected and Purpose

The Centre holds personal data on individuals, including: contact details, attendance information and photographs.

The “Centre” is part of two entities: “UWCSEA - Dover” and “UWCSEA - East” and shares administrative services with these two entities.

The data is used in order to support the provision of events and post-event feedback and other services normally associated with workshops, conferences and similar events.

The Centre may make use of limited personal data (such as contact details) relating to students, their parents or guardians and delegates for marketing or promotional purposes and to maintain relationships with participants of the Centre.

Data is shared as necessary with third party companies to provide extended services, examples include transport, medical, catering, accommodation and online services such as sign-up and event management.

In particular, the Centre:
a. will share relevant details with the certifying body in the case of courses leading to third-party certification.
b. may make use of photographs, videos or sound recordings of participants in Centre publications, the Centre website and other official Centre communication channels, as well as in external media.
c. may retain and use personal data after an event to provide post event services consistent with training events.

Data Security

The Centre undertakes to:
a. implement appropriate security measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular when the processing of data involves the transmission or storage on or within a network.

These security measures will include:

  • industry standard firewall and other network security features
  • clear guidelines for staff on the device and network security expectations placed on them
  • robust data backup and recovery processes
  • periodic external security audits of online systems

b. notify data subjects about any accidental or unauthorised access of their data that may lead to damage or harm.

Data Retention and Removal

The Centre undertakes that it shall only keep the data collected as long as is necessary to provide the services outlined above.

Right of Access and Correction

Participants have a right to see the data held about them (subject to the exemptions listed below) and to request for data to be corrected if it is incorrect.

To request for data to be changed, please contact centre@uwcsea.edu.sg.

The Centre will consider the request and respond within three working days. The response may be to decline the request with reasons or to provide a time scale in which the data will be supplied.

Exemptions to Right of Access

The PDPA does not provide the right of access to any and all information held by an organisation. Therefore the Centre retains the right to refuse access to:

  • Opinion data kept for evaluative purposes
  • Data or material that provide personal data about other individuals in contravention of this policy or the PDPA.

Sharing Data with Third Parties
The Centre shares personal data with a variety of third parties for the purposes of the third party providing a relevant service to the institution. Examples of these services include certification, transport, catering, travel services, accommodation, medical.

The Centre will only share data for the purposes of eliciting a necessary service from these third party organisations and not for commercial gain.

Where the Centre signs explicit contracts with these organisations it will include clauses from Appendix A - Contracts with Third Parties to ensure that the organisation is using the data purely for the intended purpose of providing the required service and that it is taking appropriate precautions to safeguard the data.

In some instances, for example for online services provided by companies outside of Singapore, explicit signed contracts do not exist. In these instances the Centre will ensure that the terms & conditions of the service include clauses that:

  • the Centre remains the owner of the data
  • the service provider is not entitled to use any data held on its service for any purpose other than to provide the required service
  • the service provider is taking reasonable precautions to ensure the security of the data
  • once the Centre terminates its agreement with the service provider, that any and all data held will be deleted and not used for any other purpose

Point of contact

In the event of any queries or complaints in relation to data protection, please contact dataprotection@uwcsea.edu.sg.

Appendix A - Contracts with Third Parties

When signing contracts with any third party organisations that the Centre will share personal data with the contract should include the following clauses or entries to the same effect.

Data Protection and UWCSEA

UWCSEA and UWCSEA Centre for International Education (henceforth “the Centre”) collect and use personal data about individuals in accordance with the Singapore Data Protection Act (2012) and other relevant laws and requirements on private education institutions in Singapore.

As a result of the provision of your obligations under this agreement, you may have access to personal data about the Centre’s employees and participants. You must (and must ensure that your employees, agents, sub-contractors and representatives will) keep all such data secure and protected against improper disclosure or use as detailed in this agreement.

Definitions:
a. ‘Personal data’ shall refer to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access and all other data deemed protected under the Personal Data Protection Act 2012
b. ‘PDPA’ shall mean the personal Data Protection Act (2012)
c. ‘the Centre’ shall mean the entity who transfers the data to be used
d. ‘the company’ shall mean the processor who agrees to accept the Centre’s personal data intended for processing and use in accordance with this agreement

1. Data Use

The company agrees and warrants:
a. that any personal data shared by the Centre or collected by the company as a result of providing the services covered in this agreement will be used solely for the purposes of providing the service detailed in this agreement
b. that no personal data collected or shared will be used to offer or solicit further services from the individuals concerned.
c. to process the personal data only on behalf of the Centre and in compliance with its instructions.
d. that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law and do not violate the relevant laws of the Republic of Singapore in which the Centre resides.
e. that it shall promptly notify the Centre about any request for disclosure received directly from any authority or individual.

2. Data Security

The company agrees and warrants:
a. to implement appropriate security measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular when the processing of data involves the transmission or storage on or within a network.
b. that it shall promptly notify the Centre about any accidental or unauthorised access of the data, or any loss of the data whether leading to unauthorised access or not.

3. Data Retention - Obligations after the Termination of Contract or Services

The company agrees and warrants:
a. that on the termination of the contract or services that required data processing services, that the company shall, at the request of the Centre transfer all the data transferred and copies thereof to the data exporter or shall destroy all the personal data and certify that he has done so, unless legislation imposed on the data importer prevents him from returning or destroying all or part of the data transferred. In that case the company warrants that he will guarantee the confidentiality of the personal data and will not actively process the personal data transferred anymore. Once the legal requirement for retention has passed the company warrants that it will destroy all data retained.

4. Data Correctness and Right of Correction

The company agrees and warrants:
a. to provide the Centre on request all the personal details of individuals that have been collected as the result of this agreement and to amend or delete such data on request within the lifetime of the agreement.

5. Liability

a. The parties agree that if one party is held liable for a violation of the clauses committed by the other party in contravention of the PDPA,  the latter will, to the extent he is liable, indemnify the first party from any cost, charge, damages, expenses or losses it has incurred.

 

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