1. Introduction
Your privacy is important to Arul Chew & Partners (“ACP”). ACP takes responsibility and is committed to protecting your Personal Data (as defined below) to ensure the handling of Personal Data in compliance with the provisions of the Singapore Personal Data Protection Act 2012 (“PDPA”). This policy details our approach to the protection of your Personal Data.
In the course of the provision of our services and in order to operate effectively, ACP needs to collect, use and disclose personal information about entities, including corporations and individuals, including but not limited to: personal information of current, past and prospective employees and personal information of individuals related to or provided by our individual or corporate clients.
1.1 Personal Data defined
“Personal Data” is any data or information about a person in which they can be identified
a) from that data; or
b) from that data and other information which the organisation has or are likely to have access
Examples of Personal Data which we may collect include, but are not limited to:
a) your full name, NRIC, passport number or other identification number, telephone number(s), residential and/or mailing address;
b) payment related information such as your bank statements, bank account details, credit card details and credit history;
c) education and employment data including employment status and education history;
and any other information relating to you which you have provided to us in any form, or during our interaction with you, to facilitate the provision of our legal services.
2. Collection, Use and Disclosure of Personal Data
3.1 Collection of Personal Data by ACP
Generally, ACP collects your Personal Data in the following ways:
a) when you communicate with us;
b) when you request that we contact you;
c) when you submit a job or internship application;
d) when we receive references about you from business partners and other third parties (for example when you have been referred by them); and
e) when you submit your Personal Data to us for any other reason;
and other services in the ordinary course of our work.
In the course of us providing legal services to our clients, we may collect Personal Data of individuals from parties such as our clients, service providers, professional advisors and their representatives, content providers, government authorities, public sources and records.
Where our clients provide us the Personal Data of third parties, including but not limited to our clients’ employees, any related individuals, agents, business partners and/or opponents, our clients need to obtain, if necessary, from such third parties their consent, to collect, use and disclose their Personal Data for the below mentioned purposes. (s 15A PDPA)
3.2 Use and Disclosure of Personal Data by ACP
In the course of us providing our legal services, we may need to disclose your Personal Data. Personal Data may be disclosed within ACP, to any of our existing or future related or associated individuals, entitles or companies or to any relevant third parties such as auditors, professional consultants or advisors (including other law firms), accountants, agents, insurers, government and/or statutory bodies and authorities or any other third parties which are reasonably necessary to satisfy the below mentioned purposes.
3.2 Purposes
Generally, ACP collects your Personal Data for the following purposes:
a) Provision of services, including legal services, corporate services, tax and accounting, payroll processing;
b) Client relationship management, including sending updates, disclosing information relating to our services and business, or services provided by third parties, events invitation, newsletters, publications and marketing materials;
c) Obtaining feedback for our services and events;
d) Legal and/or regulatory compliance;
e) Internal record keeping and archival purposes including as required by law and/or the Law Society of Singapore;
f) Managing and/or terminating employment relationships;
g) Evaluating employees and/or employment applications; and
h) All other purposes reasonably necessary and/or incidental to our business and all purposes reasonably necessary for or related to the abovementioned purposes.
Should your Personal Data be required for other purposes, your approval will be obtained on or prior to the collection of your Personal Data for that particular purpose, or you will be notified accordingly. (s 20 PDPA) This will be subjected to any exceptions to the consent or notification obligation pursuant to the PDPA.
3. Accuracy of Personal Data
ACP will make a reasonable effort to ensure that Personal Data collected is accurate and complete by ensuring that Personal Data is obtained from reliable and trusted sources. (s 24 PDPA)
4. Protection of Personal Data
ACP will protect your Personal Data by making reasonable security arrangements to prevent unauthorised access, collection, disclosure, copying, modification, disposal or similar risks while the Personal Data is within our possession, and we do get our computer & software technical in-charge to update our software, virus ware and relevant data protection systems regularly.
We have in place appropriate technical, organisational and administrative security measures to protect your Personal Data against unauthorised access, collection, use, disclosure, copying, alteration, accidental loss or theft, destruction, damage or other similar risks.
All employees are required to maintain confidentiality of any Personal Data ACP collects.
5. Retention of Personal Data
ACP will keep your personal data no longer than is reasonably necessary for the purpose it was collected or for any business or legal purpose, or as required by the Law Society of Singapore.
6. Transfer of Personal Data
ACP will ensure that any transfers of your Personal Data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA.
7. Your Rights
Subject to any exceptions in the PDPA, you have the right to request access to the Personal Data that we hold about you. (s 21 PDPA) If you would like a copy of some/all of your Personal Data, please send us an email at andre@arulchewlaw.com with notice of at least seven (7) working days to attend to the same.
You have the right to request that we update or correct your Personal Data that we hold about you. If any of the information that you have provided to ACP changes or if the information provided was erroneous, please send us an email at andre@arulchewlaw.com (s 22 PDPA)
You have the right to request that we do not collect, use or disclose your Personal Data in any manner described herein. You can give us notice of such intention to halt the collection, use and disclosure of Personal Data at any time by contacting us at andre@arulchewlaw.com (s 16 PDPA)
Please note that if you withdraw your consent to any/all collection, use and/or disclosure of your Personal Data, depending on the nature of your request, ACP may not be in a position to/or continue providing legal services to you. In addition, we will not be liable in any way for the consequences arising from your not giving or withdrawal of consent.
Should you have any enquires about out data protection policies and practices, or if you wish to exercise any of your rights or raise a complaint on the way ACP has managed your Personal Data, you may contact the relevant Data Protection Officer at andre@arulchewlaw.com
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