This Data Protection Policy (“Policy”) sets out the basis upon which She Loves Data Ltd. (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of volunteers in accordance with the Personal Data Protection Act (“PDPA”) or other applicable legislation (such as GDPR etc.). This Policy 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.
APPLICATION OF THIS POLICY
This Policy applies to all volunteers (collectively referred to as “volunteer”).
PERSONAL DATA
As used in this Policy, “personal data” means data, whether true or not, about a volunteer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Types of personal data
Personal data which we may collect in the context of your relationship with us includes, without limitation, your:
- name or alias, gender, NRIC/FIN/Id or passport number, date of birth, nationality, country of birth;
- mailing or contact address, telephone numbers, email address and other contact details, bank details;
- evidence of hours worked/absence as a volunteer, evidence of attendance at events organized by us or at other related events;
- employment and training history;
- volunteer-related health issues and disabilities;
- photographs and other audio-visual information;
- notes about volunteering activities and performance;
- other personal data necessary for the performance of our relationship provided by you in connection with your volunteering activities.
Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure of Personal Data
How we collect personal data
We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your volunteering with us, 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 applicable 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).
How we use personal data
Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a) performing tasks and obligations under or in connection with our relationship and your volunteering tasks;
(b) all administrative and human resources related matters within our organisation, including granting access to our premises and computer systems, processing of handover of our property or entrusted objects, processing calendars, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing internal policies;
(c) managing and terminating our relationship with you, including monitoring your use of our communication tools to investigate potential contraventions of our internal or external compliance regulations, and resolving any related grievances;
(d) assessing and evaluating your suitability for appointment in any position within our organisation;
(e) ensuring business continuity for our organisation in the event that your volunteering with us is or will be terminated;
(f) performing obligations under or in connection with the provision of our services to our sponsors, event attendees, service providers and other relevant persons;
(g) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process;
(h) facilitating our compliance with any laws, customs and regulations which may be applicable to us; and
(i) your photos and recordings (audio, video etc.) at She Loves Data events and activities or those provided by you in accordance with this Policy , both in digital or printed form may be published in various channels where we disseminate information about said activities. The photos and recordings are intended to be published online, in information and marketing materials etc.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to an agreement) 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 any contract with you).
Withdrawing consent
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 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 Coordinator/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 and effect your request within thirty (30) days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to continue our relationship. We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described 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.
Access to and correction of personal data
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, you may submit your request in writing or via email to our Data Protection Coordinator/Officer at the contact details provided below.
We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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 or other applicable laws).
Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
Protection of personal data
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures to the best of our abilities. We use access control mechanisms and we disclose personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
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.
Accuracy of personal data
We 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 Coordinator/Officer in writing or via email at the contact details provided below.
Retention of personal data
We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
We generally do not transfer your personal data to countries outside of Singapore, European Union or the country of your residence. However, your personal data may be transferred to other countries if it is necessary for the performance of your volunteer activities. For that case you hereby give us your consent for such transfer and we will take steps to ensure that your personal data continues to receive a comparable standard of protection.
DATA PROTECTION COORDINATOR/OFFICER
You may contact our Data Protection Coordinator/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: Marianna Tuckova, email: legal@shelovesdata.com, phone: +420 602 764 170.
For the avoidance of any doubts, the Data Protection Coordinator/Officer is not a Data Protection Officer in the meaning of the GDPR regulations.
EFFECT OF POLICY AND CHANGES TO POLICY
This Policy applies in conjunction with any other policies, 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 Policy from time to time without any prior notice, however we will notify you about such change. Your continued involvement in volunteering activities constitute your acknowledgement and acceptance of such changes.
Effective date: March 26, 2020
