Personal Data Protection Policy Statement 

of the Singapore Business Network on DisAbility

 

I. Introduction 

This privacy policy informs you of how the Singapore Business Network on DisAbility(“SBNoD”, “We”, “Us”, “Our”) collects, uses and discloses your personal data in connection with the use of the website www.sbnod.com(“Website”) and a LinkedIn account called […] (“LinkedIn Account”) and in the provision of the SBNoD. 

 

We process your personal data in accordance with the applicable personal data protection laws, in particular to the Singapore Personal Data Protection Act (“PDPA”).

 

The SBNoD is a network focused on sharing best practices in terms of employment of persons with disabilities. Our network has members (“Members”) and friends (“Friends”). 

 

II. Controller of the personal data 

By collecting, using and disclosing personal data to animate the Network, we, SBNoD, are the controller of the personal data. 

 

Contact details: 

Singapore Business Network on DisAbility 

Email : [alister.ongtjoe@singtel.com]

 

III. Data protection officer 

Any requests and complaints shall be addressed to our Data Protection Officer. 

 

Contact details:

Loise Jacquette

Phone: +65 6408 8000

Email :loise.jacquette@gmail.com

 

IV. Personal Data 

“Personal Data” is data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. 

 

In the course of the animation of the SBNoD and in order to operate effectively, we may collect, use and disclose personal information about individuals, including but not limited to: 

·      personal information of individuals sending us inquiries; 

·      personal information of individual featured in the articles or stories that our Members or Friends publish on our Website and our LinkedIn Account; and 

·      personal information about the employees of our Members or Friends involved with the SBNoD. 

 

SBNoD does not collect biometric data. 

 

V. Consent 

SBNoD obtains the consent, if necessary, of individual before collecting, using and disclosing Personal Data. Such consent is given via our contact us page on our Website or emails.  

 

When a Member or a Friend uses and/or discloses third parties’ Personal Data in an article or story published on our Website or LinkedIn Account,  that Member or Friend must to obtain all consents, if necessary, from such third parties to collect, use and disclose Personal Data for the purposes as set out above.  

 

VI. Purposes of collection, use and disclosure of Personal Data 

We may collect, use and disclose Personal Data for the purposes of: 

(i)           you becoming a Member or a Friend; 

(ii)          answering to a request sent to us; 

(iii)        publishing articles and stories on our Website; 

(iv)        displaying, maintaining and improving our Website and LinkedIn Account; 

(v)          sending updates, event invitations, newsletters or publications and marketing materials to our Members, Friends and Members and Friends’ employees who are involved with the SBNoD; 

(vi)        obtaining feedback for participation to our events or our network; 

(vii)       all other purposes necessary and/or incidental to our business and all purposes necessary for or related to any of the above purposes; and

 (the “Purposes”).

 

Should Personal Data be required to be used for a new purpose, your approval will be obtained prior to using your Personal Data for the new purpose or you will be notified respectively, provided that no exemption to the consent or notification obligations applies according to the PDPA. 

 

VII. Disclosure and Transfer of Personal Data 

Personal Data may be disclosed within the SBNoD, to any of its existing or future third party/ies such as auditors, professional consultants or advisors (including law firms), accountants, agents, insurers, governmental bodies and authorities or any other third party in order to satisfy the Purposes for which the Personal Data have been collected. 

 

Personal Data may also be transferred outside of Singapore in accordance with the requirements of the PDPA and in order to satisfy the Purposes for which the Personal Data have been collected. 

 

Personal Data published on our website is stored on the Cloud in the USA via our Website service provider, Squarespace Inc.

Personal Data not published on our website is stored in Singapore.

 

VIII. Protection 

Appropriate technical, organisational and administrative security measures are in place to protect Personal Data against unauthorised access, collection, use, disclosure, copy, alteration, accidental loss or theft, destruction, damage or similar risks. Our security measures are continuously improved in line with technological developments by our Website service provider.

 

All individuals involved with the SBNoD are made aware of the importance of maintaining confidentiality of the Personal Data collected from you. The access to Personal Data by our individuals involved with the SBNoD is on a need-to-know basis only. 

 

IX. Retention 

The SBNoD will keep Personal Data no longer than is necessary for the Purposes it was collected. The SBNoD will take all reasonable steps to ensure that all Personal Data is destroyed, permanently deleted or anonymised if it is no longer required for those Purposes. 

 

The SBNoD implemented policies to ensure proper destruction of confidential documents once they are no longer needed (use of shredders and/or deletion from our server). 

 

X. Accuracy 

Personal Data held by us is usually provided either by you and the SBNoD is therefore not responsible for its accuracy in the first instance. However, if there is a complaint about the inaccuracy of Personal Data kept by us that complaint can be referred to the Data Protection Officer. 

 

XI. Rights of Data Subject

You have the right to withdraw your consentto the collection, use and disclosure of your Personal Data. In the event that you have withdrawn your consent, we will advise you on the consequences of the withdrawal and will cease to use or disclose the Personal Data in case your consent is not legally required.

 

You have the right to access and correct information held about you by us and, if the details are inaccurate, you may request that the data shall be amended. The right of access and correction can be exercised in accordance with the PDPA. Any access request may be subject to a fee to meet the cost in providing you with details of the information we hold about you. Such request shall be made in writing to the Data Protection Officer at the address indicated above. 


 

XII. Use of our Website and Cookies  

The SBNoD uses the services of Squarespace, Inc, our Website service provider, which assist with the display, maintenance and improvement of our Website. Personal Data collected via our website is controlled by the SBNoD and processed by Squarespace.  

 

By accessing or using the Website, you agree to the terms of this Policy and consent that we will collect, use and share your information in the following ways: 

 

(a) Our Cookies

Different pages of our Website use cookies. The use of cookies is solely to make the visit to our website more attractive and to enable the use of certain functions. We do not use cookies to create user profiles or to evaluate user behaviour.  

Cookies are small text files that are stored on your computer. Most of the cookies we use are deleted from your hard drive after the end of the browser session (so-called session cookies). In addition, we offer the option of storing certain cookies, optionally and on a voluntary basis, for a longer time to further enhance your user experience. Cookies can be blocked in your browser. However, if cookies are blocked, parts of our website may no longer function correctly. 

The cookies active on our website are as follows: 

cookies.png

The legal basis for the use of cookies is our legitimate interest to offer you a user friendly website. 

 

(a) General information collected when you visit our website

Our website collects from the visitor the following general data and information each time it is accessed by a person or an automated system which are stored in the log files of the server: 

(1) the browser types and versions used; 

(2) the operating system used by the accessing system;

(3) the internet page from which an accessing system accesses our website (so-called referrers); 

(4) the sub-web pages which can be accessed via;

(5) the date and time of access to the website;

(6) an Internet Protocol address (IP address);

(7) the Internet service provider of the accessing system; and 

(8) other similar data and information used in the event of attacks on our information technology systems.

 

When using this general data and information, we do not draw conclusions about the person concerned. Rather, this information is required to:  

(1) correctly deliver the contents of our website; 

(2) to optimize the content of our website and to advertise it; 

(3) to ensure the continued functioning of our information technology systems and the technology of our website; and 

(4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyberattack. 

 

The anonymous data of the server log files are stored separately from all personal data provided by you.

 

(b) Order and contact forms

For questions of any kind, we offer you the opportunity to contact us via the form provided on our Website. 

 

In order for us to answer your question, we must collect from you your name and valid e-mail address. The Personal Data collected by us via the contact forms will be used exclusively to process your request.

 

To answer to your request, it may be necessary for your Personal Data to be processed via third parties IT service providers (e.g. email management platforms like Outlook).

 

The legal basis for the processing of your Personal Data is your voluntarily consent. 

 

(c) Third parties’ Cookies 

YOUTUBE 

We include on our website videos from the YouTube platform of Google LLC. 

 

Video transmission to your device always requires that YouTube receives and caches the users’ IP address, as they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. For this purpose, data collected by YouTube for statistical analysis, includes: 

(1) IP address, 

(2) country of origin, 

(3) localization based on IP, 

(4) operating system, 

(5) browser, 

(6) screen resolution. 

 

YouTube’s cookies are set. If you’re also logged in to your browser with your Google Account, Google can associate the View with you. For more information, please contact Google. Privacy Policy: https://www.google.com/policies/privacy/

To opt-out: https://adssettings.google.com/authenticated

 

(d)  Security of the website 

The SBNoD uses SSL (Secure Socket Layer) encryption within our website, in conjunction with the highest level of encryption supported by your browser. In general, we use a 256-bit encryption. If your browser does not support 256-bit encryption, we will use 128-bit v3 technology instead. Whether a single page of our website is transmitted in encrypted form is indicated by the closed padlock symbol in the status bar of your browser.

 

(e) External links 

This site may contain links to third parties’ sites whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult their privacy notices.

 

XIII. Amendment of Privacy Policy 

We reserve the right to change or amend this Personal Data Protection Policy from time to time at our sole discretion. The revised Policy will be available from the Data Protection Officer upon request and this webpage.

 

October 2018