Data Protection Notices
These Data Protection Notices (“Notice”) sets out the basis which Caritas Humanitarian Aid & Relief Initiatives Singapore (“CHARIS”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of persons in accordance with the Personal Data Protection Act (“PDPA”) and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission (PDPC) of Singapore. 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 otherwise process personal data for our purposes.
Personal Data Protection Policy
- Introduction
- Caritas Humanitarian Aid & Relief Initiatives (Singapore) Ltd. (collectively referred to herein as “CHARIS”, “we”, “us”, “our”) is committed to protecting the privacy of individuals who provide personal information to us, including those information provided through our websites within charis-singapore.org domains.
- This Data Protection Notice (“Notice”) sets out the basis which CHARIS may collect, use, disclose or otherwise process personal data of our prospective Service Users (including but not limited to users of our electronic platforms, donors, beneficiaries, participants and volunteers in our events and activities, and Service Users’ representatives) 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.
- Collection, use, disclosure or otherwise processing of personal data of our service users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. CHARIS will comply with the relevant requirements under the government’s data management policy.
- Personal Data
- As used in this Notice: “personal data” means data, whether true or not, about a Service User, 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 which we may collect from you include name, contact information such as residential address, email address or telephone number, nationality, gender, date of birth, marital status, medical history, photographs and other audio-visual information, employment information, financial information such as credit card numbers, debit card numbers or bank account information and 3rd party personal data.
- 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 usage 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 which has not been notified to you (except where permitted or authorised by law).
- We may collect and use your personal data for any or all of the following purposes:
- Establishing or managing your relationship with us. This includes:
- Where you are a prospective user, processing and evaluation of your application for our services.
- Where you are a Service User,
- providing the services requested by you;
- monitoring, evaluating and/or auditing of services provided. This may include an assessment of 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); and
- research related to your personal circumstances or services you used, in particular, for our research entitled. 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. For processing; administration and evaluating the Service User’s application for our services; events; activities; programmes.
- Where you are a donor for us to process your donation and provide acknowledgement for the donation.
- Where you are a volunteer,
- processing and evaluating your suitability to volunteer; and
- monitoring, evaluating and/or auditing of services you participated in.
- providing you with information on our upcoming events or activities, where you have specifically requested to receive such information;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
- 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 affiliated third party including our Member Organisation, Partner Organisation and/or The Roman Catholic Archdiocese of Singapore whether in Singapore or abroad, for the aforementioned purposes;
- 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;
- any other incidental purposes related to or in connection with the above; and
- raise awareness of the work done by CHARIS and its member organisations by using your personal data. This includes but is not limited to photos/videos taken at the CHARIS and its member organisations activity/event for publicity on various local online and print media platforms; on our Catholic Archdiocesan platforms; as well as global Caritas platforms.
- IP Addresses
- When you use our website, we may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about our users' browsing actions and patterns. This data could possibly lead to your identification, but we, and our data intermediaries, do not use it to do so unless permitted by law.
- Cookies
- Cookies are small files which are placed on your computer when you access a website or app – amongst other things; they help the website user to navigate efficiently between pages and the website operator to track usage of the site. You can find out more about cookies at www.allaboutcookies.org.
- Our website uses cookies to distinguish you from other users of our website by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our website and the location from which you are accessing the website). Note that some limited information is personally identifiable for the purposes of:
- managing and customizing your experience on the website/platform;
- analysing trends and improving our site for our users; and
- delivering content tailored to your interests and the manner in which you browse our websites and platforms.
- Any other information is anonymized and/or aggregated to produce statistical reports that enable us to evaluate the use of our website; and to make improvements to, and increase efficiency when you browse our website.
- What do we use Cookies for?
- We use cookies to keep track of the following information:
- Tracking cookies
- Google analytics cookies, subject to Google’s Privacy Policy
- Recent views: Campaigns and Events you have recently visited
- Third-party media sharing cookies
- YouTube, subject to Google’s Privacy Policy
- Technically necessary cookies
- Session ID: protects our users and services against certain attacks (known as cross-site request forgery/CSRFs)
- Shopping Cart Identifier: retains your cart information, only if you have added items to your cart
- Time zone Offset: your system time zone setting, which helps us to display times appropriately
- Login Secure, Remember Login, and Auth: these are used to support secure login to Make Hope Happen
- COC Catholic Tracking: to track if user has agreed to the terms for funding request in accordance to fundraising permit.
- We use the information collected to analyse trends and improve our site for our customers, as more particularly described below.
- What are my options in relation to the use of Cookies?
- By using our website, apps or platforms, you agree to the use of cookies and other technologies as set out in this Privacy Statement. If you do not agree to such use please either refrain from using the relevant website, app or platform, or see the section below “Can you disable cookies?” to adjust your settings.
- Can you disable Cookies?
- Your browser will enable you to disable, control or delete cookies if you wish. Further information can be found in the “Help” section of your browser or at www.allaboutcookies.org. However, you should note that if you choose to do this, it may have an impact on the quality of your browsing experience.
- Please note that changing these settings may limit the functionality of some web pages or prevent them from loading properly. Additionally, the major browsers have attempted to implement the draft “Do Not Track” (DNT) standard of the World Wide Web Consortium in their latest releases. As this standard has not been finalized, this website is not compatible with DNT and does not process DNT messages.
- To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
- Third Party Websites
- Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- Third parties (including, for example, CHARIS Member Organisation websites, advertising networks and providers of external services like Google Analytics) may use cookies which are downloaded when you visit our site. These cookies are likely to be analytical, performance or targeting cookies.
- We may disclose your personal data:
- where such disclosure is required for, or in connection with, the provision of the services requested by you;
- to our Member Organisation, Partner Organisation and/or The Roman Catholic Archdiocese of Singapore to perform any of the purposes listed in clause 3.2 above;
- to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 3.2 above for us;
- to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations; and
- any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us 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).
- 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 or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email or otherwise in writing to our Data Protection Officer at the contact details provided below. If you are unable to submit your request in writing or if you require any assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
- 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 fourteen (14) 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. Should you decide to cancel your withdrawal of consent, please inform us in the manner described in clause 4.1 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.
- 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 via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
- 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 ten (14) 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).
- 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, encryption, and disclosing personal data internally, our Member Organisation and to our authorised third party service providers and agents 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, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- 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 editing your profile on makehopehappen.charis-singapore.org or by informing our Data Protection Officer at the contact details provided below.
- 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.
- We generally do 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.
- If you wish to make a deletion request for personally identifiable data which we hold about you, you may submit your request via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
- Please note that a reasonable fee may be charged for a deletion 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 ten (14) 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 remove any data 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).
- Whilst we respect your rights to remove or delete all your personally identifiable data from our system, please note that 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. Should you decide to cancel your deletion request, please inform us in the manner described in clause 4.1 above.
- You may contact our Data Protection Officer via dpo@charis-singapore.org 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 event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate, report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required.
- 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. This privacy statement does not apply to websites of third parties that are connected to this website by means of web links.
- We reserved the right to 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.