Data Protection Notice
This Data Protection Notice (“Notice”) sets out the basis which SHATEC Institutes Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers 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.
Also refer to ‘ADVISORY GUIDELINES ON KEY CONCEPTS IN THE PERSONAL DATA PROTECTION ACT’ Issued 23 September 2013, Revised 16 May 2022.
PERSONAL DATA
As used in this Notice:
a. Personal data is defined in the PDPA as “data, whether true or not, about an individual who can be identified — a) b) from that data; or from that data and other information to which the organisation has or is likely to have access”.
b. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
DATA PROTECTION OBLIGATIONS
1. ACCOUNTABILITY
SHATEC undertake measures to ensure that our organisations meet the obligation under the PDPA such as making information about your data protection policies, practices and complaints process available upon request and designating a data protection officer (DPO) and making the business contact information available to the public. SHATEC shall:
(a) develop and implement policies for data protection;
(b) communicate and inform our staff about these policies, and inculcate an organisational culture of responsibility among staff through regular training and awareness programmes;
(c) appoint a Data Protection Officer (DPO) who is tasked with ensuring that our organisation complies with the PDPA. Additionally, make information about our data protection policies and practices available to our stakeholders; and
(d) implement processes and practices that are necessary to meet our obligations under the PDPA. Our organisation will demonstrate that personal data is properly managed and protected. This includes adapting legal requirements into policies and practices, data protection by design, and using monitoring mechanisms and controls to ensure that policies and processes are effectively implemented.
Above all, as an accountable business, our organisation is answerable to regulatory authorities, business partners, and individuals who entrust the organisation with personal data.
2. NOTIFICATION OBLIGATION
SHATEC 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).
3. CONSENT OBLIGATION
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 in writing. You 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 in writing or via email to our Data Protection Officer at the contact details provided below.
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 ten (10) 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 writing in the manner described in clause 8 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.
4. PURPOSE LIMITATION OBLIGATION
SHATEC may collect and use your personal data for any or all of the following purposes:
i. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
ii. verifying your identity;
iii. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
iv. managing your relationship with us;
v. processing payment or credit transactions;
vi. 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;
vii. any other purposes for which you have provided the information;
viii. 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; and
ix. any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
i. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
ii. to third party service providers, agents, and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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).
5. ACCURACY OBLIGATION
SHATEC 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 informing our Data Protection Officer in writing or via email at the contact details provided below.
6. PROTECTION OBLIGATION
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, SHATEC has introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
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.
7. RETENTION LIMITATION OBLIGATION
SHATEC 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. SHATEC shall make reasonable effort to ensure that the personal data collected is accurate and complete. 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 in writing or via email to our Data Protection Officer at the contact details provided below.
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 thirty (30) 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).
8. TRANSFERS LIMITATION OBLIGATION
SHATEC undertake an appropriate level of due diligence to assure itself that a potential data intermediary is capable of complying with the PDPA. When engaging a data intermediary, SHATEC shall make clear in its contract the scope of work that the data intermediary is to perform on its behalf of SHATEC and for its purposes.
SHATEC shall ensure that our appointed “recruitment agents” are made aware of and exercise proper data protection practices in relation to the handling of personal data.
SHATEC 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.
SHATEC ensures that personal data transferred overseas is protected to a standard comparable with the Data Protection Provisions. The onus is on the transferring organisation to undertake appropriate due diligence and obtain assurances when engaging a data intermediary to ensure that it is capable of doing so. In undertaking its due diligence, transferring organisations may rely on data intermediaries’ extant protection policies and practices, including their assurances of compliance with relevant industry standards or certification.
9. DATA BREACH NOTIFICATION OBLIGATION
SHATEC shall also demonstrate as an organisation that can detected a data incident early and demonstrated that it has established processes to respond to it quickly and effectively may submit to the PDPC an undertaking to voluntarily commit to implement its remediation plan and resolve the breach.
10. DATA PORTABILITY OBLIGATION
SHATEC shall at the request of the individual, organisations will transmit the individual’s data that is in the organisation’s possession or under its control, to another organisation in a commonly used machine-readable format.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer 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 following manner:
Contact No. : 64153588
Email Address : dpo@shatec.sg
EFFECT OF NOTICE AND CHANGES TO NOTICE
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.
We may 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.
Effective date : 28/01/2025
Last updated : 28/01/2025
ADVISORY GUIDELINE FOR THE EDUCATION SECTOR
INTRODUCTION
This Advisory is jointly developed by the Personal Data Protection Commission (“PDPC”) and the Ministry of Education (“MOE”). It aims to address the unique circumstances faced by organisations in the education sector in complying with the PDPA and it applies to education institutions, insofar as they are not excluded from the application of the PDPA (see paragraph 1.4).
The PDPA defines an “education institution” as an organisation that provides education, including instruction, training, or teaching, whether by itself or in association or collaboration with, or by affiliation with, any other person. This includes education institutions within MOE’s education system which are not owned by the Government, such as Government-aided schools, independent schools, specialised independent schools and specialised schools. It also includes privately-funded schools, autonomous universities, early childhood development centres (“preschools”) licensed with the Early Childhood Development Agency and other registered private education institutions (“PEIs”).
SCOPE OF EXCETIONS TO CONSENT OBLIGATION
Under Section 17 of the PDPA permits the collection, use and disclosure of personal data without consent (and in the case of collection, from a source other than the individual) and enumerates the permitted purposes in the First and Second Schedules to the PDPA. Even if an exception applies under the PDPA, organisations are required to comply with other legal obligations, for example, to protect confidential information.
Some of these exceptions include:
a. the collection, use or disclosure of personal data about an individual is necessary to respond to an emergency that threatens the life, health, or safety of the individual or another individual;
b. the collection, use or disclosure of personal data about an individual is publicly available;
c. the collection, use or disclosure of personal data is necessary for evaluative purposes;
d. the collection and use of personal data, where the personal data was disclosed by a public agency and the collection and use of the personal data by the organisation are consistent with the purpose of the disclosure by the public agency;
e. the disclosure of personal data to a public agency, where the disclosure is necessary in the public interest;
f. the disclosure of personal data about an individual who is a current or former student of an education institution to a public agency for the purposes of policy formulation or review; and
g. where the collection, use or disclosure of personal data about an individual is in the legitimate interests of the organisation or another person and the legitimate interests of the organisation or other person outweigh any adverse effect on the individual.
Version: Revisions to Advisory Guidelines (updated 25 April 2024)
The Advisory Guidelines have been updated to take into account the amendments to the PDPA and the Personal Data Protection Regulations which came into force on 1 February 2021.
Effective date : 28/01/2025
Last updated : 28/01/2025