i. This Policy statement provides information on the obligations and policies of CFS in respect of an individual customer’s Personal Data. CFS undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
ii. CFS’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, CFS. CFS shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by CFS shall be done in an appropriate manner and in accordance with the Act and this Policy.
iii. For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of CFS or that which shall be collected by CFS in future.
2. Contacting the Data Protection Officer
i. Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of CFS, CFS shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
ii. In accordance with the Act, CFS has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that CFS receives your complaints and enquiries, please send the same via email to CFS at the following email address: firstname.lastname@example.org
iii. Should you not wish CFS to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from CFS, you may opt out by sending a clearly worded email to CFS via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected:
i. As part of its day-to-day activity, CFS may collect from you, through various means, including via our programmes, centres/branches, websites, application forms and any other forms used by CFS from time to time, some or all of the following Personal Data:
• Name (first and surname);
• Postal Address;
• Phone number (including mobile);
• Office number;
• Fax number;
• Email address;
• Bank account/credit card details;
• Personal Data of your emergency contacts;
• IP addresses; and
• Photographs and images
• Medical records
• Caregivers contact and address
• Household income
• Employment details
• Next of kin information
Purpose of Collection of Personal Data
ii. The above Personal Data mentioned in Clause 3.1 is collected for the purposes of processing your application and registration of you as a user of CFS services and to ascertain if you are eligible for government subsidies, discounts or other related purposes; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification purposes; for maintaining and updating your personal details; to evaluate if you are suitable for employment within CFS or the NTUC group; and informing you of new services of CFS and other third parties which we are associated with.
Disclosure of Personal Data
iii. In order to carry out the functions described above, CFS may, from time to time, disclose your Personal Data to CFS’ centres/branches and related corporations/partners.
iv. Without derogating from any of the above, CFS may also disclose your Personal Data to the following third parties:
• Regulators and law enforcement officials;
• Government appointed agencies;
• Third party service providers and consultants;
• Credit, debit and charge card companies, banks and other entities processing payment;
• Any agent or subcontractor acting on CFS’s behalf for the provision of CFS’ services including doctors, nurses, dentists, delivery personnel, suppliers and web administrators.
v. CFS may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
• To the extent that CFS is required to do so by the law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise or defend CFS legal rights;
• To the purchaser (or prospective purchaser) of any business or asset which the CFS is (or is contemplating) selling;
• To any person and/or entity for the purpose of processing such information on CFS’ behalf;
• To third parties who provide services to CFS or on its behalf;
• To any third party that purchases CFS or CFS business or any part of CFS or CFS’ business;
• With your consent; and
• For the purposes of disaster recovery.
Optional Provision of Personal Data
vi. In some instances, you may also be requested to provide certain Personal Data that may be used to further improve CFS’ services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent CFS from providing the service to you. This type of data includes, but is not limited to:
• Education and Profession;
• Hobbies and leisure activities;
• Salary range and employment details;
• Family and household demographics;
• And other related products and services subscribed to.
vii. Under certain circumstances, telephone calls made to any of CFS’ centres/branches are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
4. Accuracy of Personal Data
Where possible, CFS will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, CFS is able to validate the data provided against pre-existing data held by CFS. In some cases, CFS is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of CFS please inform us of any updates of any parts of your Personal Data by sending an email to CFS at the email address provided at Section 2.2.
5. Protection of Personal Data
CFS uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside CFS, other than to you or as described in this Policy. However, CFS cannot ensure or warrant the security of any information you transmit to CFS and you do so entirely at your own risk. In particular, CFS does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of CFS’ physical, technical, or managerial safeguards.
6. Access and Correction of Personal Data
6.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a. check whether CFS holds any Personal Data relating to you and, if so, obtain copies of such data; and
b. require CFS to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
6.2 CFS reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 6.1.Upon payment of the requisite fee, your request shall be processed within a reasonable time.
If you wish to verify the details you have submitted to CFS or if you wish to check on the manner in which CFS uses and processes your personal data, CFS’ security procedures mean that CFS may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, and NRIC or Passport or Fin number.You must therefore keep this information safe as you will be responsible for any action which CFS takes in response to a request from someone using your personal details.
7. Storage and Retention of Personal Data
CFS will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of CFS. The Personal Data is deleted from CFS’ electronic, manual, and other filing systems in accordance with CFS’ internal procedures and/or other agreements. For Personal Data provided for employment purposes, such Personal Data will be retained by CFS for a period of only 3 months following the application.
8. Contacting you
To the extent that any of the communication means which you have provided CFS with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing of the Consent form, or by any other means of indication, you hereby grant CFS your clear and unambiguous consent to contact you using all of your communication means you have provided to CFS including using via voice calls, SMS, Whatsapp or other social apps, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of CFS promotional rates and services.
9. Change Policy
CFS reserves the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by CFS. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
11.1 This Policy only applies to the collection and use of Personal Data by CFS. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. CFS does not share your Personal Data with third party websites. CFS is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
11.2 CFS will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to CFS’ website.