Privacy Policy - Peter Leow Consulting Pte. Ltd.

Privacy and Data Protection Policy

1. Introduction

1.1 Peter Leow Consulting Pte Ltd (“PLCO” or “we” or “our” or “us”) takes its responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data, and we are committed to protect the privacy of your personal data. Please read this policy to understand what personal data is collected or processed by us, and for what purposes it is used for.

1.2 “Personal data” means data, whether true or not, about a living 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. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).

1.3 The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us, that we receive through third parties or that is in our possession.

1.4 By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and are consenting to the collection, use, processing and disclosure of your personal data as described in this policy.

1.5 Without prejudice to any of the foregoing, if you provide the personal data of any other third party to us, you warrant and agree that such third party has fully read and understood this policy, and has consented to you disclosing his/her personal data to us for the collection, use and disclosure by us as described in this policy.

2. Definition of Data Protection Terms

Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.

Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on behalf of the Company.

Personal data means any data relating to a living individual who can be identified from that data. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way.

Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

3. Types of Personal Data We Collect

3.1 PLCO collects information about you when you use our website(s)/mobile application(s), forms, customer due diligence questionnaire, and/or other channels and throughout other interactions, communications and services you have with us.

(a) your personal information such as your name, NRIC/FIN/Passport number, date of birth, marital status, gender;
(b) your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;

4. Purposes for which the Personal Data is Collected, Used and Disclosed

(a) For the supply of our professional services that we render to you or that you may request, obtain or engage through us;
(b) For identification and verification purposes in connection with any of our professional services that may be supplied to you by us or that you may request from us;
(c) To carry out your instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) you or on your behalf, including contacting you via phone/voice call, text message and/or fax, email and/or postal mail regarding your instructions, enquiries and/or feedback.
(d) To contact you or communicate with you via various modes of communication such as phone/voice call, text message and/or fax message, forms, email and/or postal mail for the purposes of rendering our professional services to you, which includes annual or monthly submission to the Accounting and Corporate Regulatory Authority (ACRA) and Inland Revenue Authority of Singapore (IRAS), or any other Government Agency. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(e) To process and issue certificates after the completion of the course(s)/certification programme(s)/qualification(s) that you have registered with us;
(f) To carry out due diligence or other screening activities (including security and background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(g) To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests or dealing with and/or investigating complaints;
(h) To comply with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
(i) To comply with or as required by any request or direction of any governmental authority; or respond to requests for information from hospitals, embassies, public agencies, ministries, statutory boards or other similar authorities (including but not limited to the Ministry of Defence, Ministry of Trade and Industry, Ministry of Education, Immigration and Checkpoints Authority, Ministry of Health, Ministry of Home Affairs, Ministry of Manpower, Ministry of Foreign Affairs, Ministry of Social & Family Development and Central Provident Fund Board);
(j) To disclose to a third party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any jurisdiction, which may be within or outside Singapore;
(k) To help us improve our services to you; and/or
(l) To store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore.

(collectively, referred to as the “Purposes”)

(a) our associated/affiliated organisations or related corporations;
(b) any of our collaborative partners, agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and
(c) third parties to whom disclosure by PLCO is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

4.3 We may share your information with any member of our CPA group (which means our affiliates) from time to time for one or more of the Purposes.

4.4 We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

4.5 We may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

5. Storage of Personal Data

5.1 Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information.

5.2 We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.

6. Withdrawal of Consent for Marketing Purposes

6.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting our Data Protection Officer. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you on our website(s) or website(s)/mobile application(s). Do note that your withdrawal of consent will not affect our ability to collect, use or disclose your personal data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.

7. Data Access and Correction

7.1 You have the right to access and/or correct any personal data that we hold about you, subject to the requirements of the PDPA. If you would like to request for a copy of your personal data being held by us (such right being subject to applicable exemptions), or to update and/or correct the personal data which you have previously provided to us, you may write to our Data Protection Officer at the contact details provided below.

7.2 We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

7.3 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.

7.4 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request. We will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

8. General

8.1 Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to PLCO with regard to processing of your personal data.

8.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

9. Data Protection Officer

9.1 For any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may write in to our DPO:

Irene Chong (Ms)
Peter Leow Consulting Pte Ltd
Vision Exchange
#24-01, 2 Venture Drive
Singapore 608526
Email: irene@plco.com.sg

10. Effect of Notice and Changes to Notice

10.1 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.

10.2 PLCO reserves the right to change this policy with or without notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.

10.3 Your continued use of our professional services constitutes your knowledge and acceptance of such changes.

Effective date: 17/03/2022
Last updated: 17/03/2022