Pro Bono SG respects the privacy of individuals and recognises 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.
This Data Protection Notice (“Notice”) sets out the basis which we may collect, use, disclose or otherwise process personal data of our prospective service users, service users, service users’ authorised representative, donors, volunteers 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.
Collection, use, disclosure or otherwise processing of personal data of our service users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. We will comply with the relevant requirements under the government’s data management policy.
2. PERSONAL DATA
In this Notice, “personal data” means data, whether true or not, about an individual 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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
- Identification numbers such as NRIC, FIN, work permit
- Contact information such as residential address, email address or telephone number;
- Education, financial and/or medical records; and
- Any other personal information voluntarily provided by you for the relevant purpose(s).
3. COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
We collect personal data from individuals in accordance with the PDPA.
Generally, we will notify you of the purpose(s) for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes.
The provision of your personal data to us is voluntary, but if you do not provide the personal data as may be required in the circumstances, we may not be able to provide the services requested.
If you provide us with any personal data relating to a third party, by submitting such information to us, you warrant that you have informed the individuals of the purposes for which we are collecting their personal data and that they have consented to your disclosure of their personal data to us for those purposes.
4. PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We may collect, use and/or disclose your personal data for any or all of the following purposes (collectively known as “the Purposes”):
a. establishing or managing your relationship with us. This includes:
Where you are an applicant seeking legal assistance
- processing and evaluating your application for our services
Where you are receiving / have received legal assistance
- providing the services requested by you; and
- monitoring, evaluating and/or auditing of services provided. This may include an assessment of the quality of the services provided and the effects of the services provided (both in the short and long term, and after you have stopped using the services).
Where you are a donor
- processing your donations and your tax-deduction claims
Where you are an employee / volunteer
- processing and evaluating your suitability for the role applied for;
- managing all HR and employment-related matters; and
- monitoring, evaluating and/or auditing of services you are involved in.
b. verifying your identity;
c. responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
d. 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;
e. internal compliance monitoring and audit reviews;
f. any other purposes for which you have provided the information;
g. 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
h. any other incidental purposes related to or in connection with the above.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data:
a. where such disclosure is required for, or in connection with, the provision of the services requested by you or for any of the purposes listed above;
b. to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 4 above for us;
c. to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations; and
d. any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you.
6. WITHDRAWAL OF 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 or your authorised representative in writing.
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 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 the manner described below.
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.
7. ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA
You may request to access and/or correct your personal data currently in our possession or withdraw your consent for the collection, use and/or disclosure of your personal data at any time.
As it is essential for Pro Bono SG to have sufficient information in order to efficiently process your request, the request should include (download Request Form here):
- Full name
- Nature of request
- Contact details
You may submit your request through the following methods:
(a) written request by email to: DPO@probono.sg
(b) written request delivered to: Pro Bono SG, 1 Havelock Square #B1-18, State Courts, Singapore 059724
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. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing 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. PROTECTION OF YOUR PERSONAL DATA
We will protect your personal data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk.
We will adopt appropriate administrative, physical and technical measures to fulfill this obligation, including:
(a) up-to-date antivirus protection
(b) disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis
(c) limiting access to work areas by appropriate security measures;
(d) requiring staff and volunteers to be bound by confidentiality obligations;
(e) provide training for staff and volunteers on the PDPA to equip them with the knowledge and basic skills to ensure PDPA compliance; and conducting regular training sessions for staff and volunteers to impart good practices in handling personal data.
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.
9. ACCURACY OF PERSONAL DATA
You shall ensure that all Personal Data submitted to us is complete, accurate and correct. Please note that if you fail to do so, we may not be able to provide you with the services requested.
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 at the contact details provided below.
10. RETENTION LIMITATION OBLIGATION
We 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.
11. TRANSFER LIMITATION OBLIGATION
We 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.
12. CONTACT INFORMATION
We have appointed a Data Protection Officer (the “DPO”) to oversee the management of personal data in accordance with the PDPA. If you, at any time, have any queries on this policy or any other queries in relation to how Pro Bono SG may manage, protect and/or process your personal data, please do not hesitate to contact the DPO at: DPO@probono.sg.
13. EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your personal data.
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.