In connection with the Personal Data Protection Act (No. 26 of 2012) (“the Act”), this Policy sets out how we, Singapore Chinese Orchestra Company Limited (SCO), manage personal data which is subject to the Act.
The security of the individual’s personal data is important to SCO. This Policy describes how we collect, use, disclose, process and protect the personal data.
When the individual visits the Singapore Chinese Orchestra/Singapore Conference Hall/Singapore National Youth Chinese Orchestra websites or request a service from SCO, the use or continued use of the services shall be deemed as the individual’s acceptance and agreement to be bound by the provisions of this Policy
This Policy supplements but does not supersede nor replace any other consent the individual may have previously provided to us in respect of his personal data.
- COLLECTION AND USE
1.1 SCO may collect personal information from you which SCO require in order for SCO to provide our services to you, for a purpose authorised by you or for purposes that are reasonably appropriate:
(a) Your name, NRIC, passport or other identification number, personal telephone number(s), personal mailing address, personal email address, bank account number;
(b) photos, film, CCTV and/or video recordings of the individual;
(c) information about the individual’s use of SCO websites, including cookies, IP addresses, etc.
(d) any other information relating to you which you have provided SCO in any forms you may have submitted to SCO, or in other forms of interaction with you.
1.2 SCO collect and use the personal data for the following purposes:
(a) To assist you with your enquiries or feedback;
(b) To send you marketing, advertising and promotional information and materials through the SCO mailing broadcast and/or social media platforms of future offers, promotions and events that SCO, our partners and/or third-party organisations with whom SCO is collaborating, may be selling or marketing;
(c) To manage administrative matters on your ticket purchases, membership, donations and processing your sign-ups/registrations for events, activities or mailing lists notwithstanding;
(d) To notify you of any changes to SCO policies or services which may affect you;
(e) To administer any contests, quizzes or lucky draw, whether organised by SCO or in conjunction with third parties, which you have participated in, including but not limited to awarding of prizes;
(f) To conduct market research and analysis including customer satisfaction or other surveys and polls to develop or enhance SCO programmes and services;
(g) To take photographs and videos of audience at events or concerts organised and hosted by SCO;
(h) To manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances when required;
(i) To manage venue booking of the Singapore Conference Hall;
(j) To process payment and accounts management;
(k) To conduct recruitment and facilitate employment;
(l) To comply with laws, regulations, guidelines, directions and other similar requirements;
In order to conduct the business operations more smoothly and to fulfil the above-said purposes, SCO may also disclose the personal data you have provided to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing the personal data either on the behalf of SCO or otherwise, for one or more of the above-stated purposes.
Arrangements are in place to protect the security of any personal data shared.
- DISCLOSURE TO THRID PARTIES
2.1 SCO will not disclose your personal data to third parties without first obtaining your consent permitting SCO to do so. However, please note that SCO may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) To provide services to you or in the management, operation and administration of SCO’s business and who are similarly bound to hold your data in confidence, including but not limited to an intern, employee, independent contractor or data intermediary providing services to support SCO, whom are under a duty of confidentiality to SCO;
(b) As required to do so by law or in the good faith belief that such disclosure is reasonably necessary: (i) comply with legal process such as if required by any court, tribunal, regulator, government regulatory bodies or relevant authority, upon production of written authorisation signed by the head or director of that agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; (ii) respond to claims that any of personal data provided to us violates the rights of third parties; (iii) protect our rights, property, or personal safety and that of the public; (iv) when the disclosure is to a public agency and such disclosure is necessary in the public interest;
(c) Where such disclosure without your consent is permitted by the PDPA or by law; or
(d) When the disclosure is necessary to respond to an emergency that threatens the life, health or safety of you or another individual.
3.1 To safeguard your personal data, all electronic storage, hosting, processing, transmission and backup (for disaster recovery or otherwise) of personal and other information are secured with appropriate administrative, physical and technical security measures. You acknowledge and consents that SCO may make use of cloud services within or outside Singapore (which may be managed by a third party service provider). While SCO take reasonable efforts to maintain the confidentiality and security of the personal data, SCO cannot guarantee that any information that is transmitted or stored electronically is completely secure.
3.2 Although every reasonable effort has been made to ensure that all personal data will be so protected, you should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, SCO strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
4.1 SCO will retain the personal data (both physical and digital records) for as long as it is necessary to fulfil the purpose for which it was collected, or as required for legal or business purposes. Any personal data which are no longer needed for legal or business purposes will be destroyed or anonymised according to the document retention policy.
- INTERNATIONAL TRANSFER
5.1 SCO generally do not transfer your personal data to countries outside of Singapore. However, if it is required, SCO will obtain your consent for the transfer to be made and SCO will take steps to ensure that the personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
5.2 If you use SCO’s services while you are outside Singapore, your personal data may be transferred to Singapore in order for SCO to provide you with those services.
6.2 SCO uses Google Analytics to analyse the use of our websites (www.sco.com.sg, www.sch.org.sg, www.snyco.com.sg). Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to SCO website is used to create reports about the use of the websites. Google will store this information. If the individual wants to opt out of Google Analytics, the individual can download and install the add-on for his web browser (https://tools.google.com/dlpage/gaoptout).
6.3 SCO may also include third party links on our website for your convenience and information. These linked sites have separate and independent privacy policies. SCO therefore have no responsibility or liability for the content and activities of these linked sites and SCO encourages you to consult the privacy notices of those sites.
- ACCESS, REVIEW AND CORRECTION
7.1 You have the right to request access to, update and/or correct your personal data held by SCO.You should contact the SCO Data Protection Officer (details under Section 10) and provides details of your access, update and/or correction request. SCO may, upon written request, allow you to view stored personal information subject to legal requirements. SCO will respond to such request within 30 days of receipt of your written request.
7.2 You should inform SCO in writing if any personal information which SCO hold about your needs to be corrected or updated.
(a) For general update : firstname.lastname@example.org
(b) For donor and sponsors : email@example.com
(c) For marketing and Friends of SCO : firstname.lastname@example.org
7.3 The PDPA exempts certain types of personal data from being subject to your access or correction request. Please refer to the Fifth Schedule of the PDPA which specifies the exceptions from access requirement and Sixth Schedule which specifies the exceptions from correction requirement.
8.1 You may, subject to applicable law, regulations and professional standards, at any time, give us reasonable written notice of your withdrawal of consent to collect, use or disclose the personal information. If you choose to withdraw your consent to any or all or the disclosure of your personal data, please note that we may not be in a position to continue providing our services to you. Withdrawal may also result in the termination of any agreement you may have with us.
- CHANGES TO PRIVACY STATEMENT
9.1 SCO will amend this Statement from time to time and the updated versions will be posted on our website and date stamped so that you are aware of when the Statement was last updated. SCO encourages all users to periodically review our website for the latest information on our privacy practices. Continued use of our services and website following the posting of changes to this Statement shall constitute your consent to such changes.
- INQUIRIES AND COMPLAINTS
If you require more information relating to this Statement or complaints, please contact us at:
Ms Teo Bee Lan
Data Protection Officer
Singapore Chinese Orchestra Company Limited
7 Shenton Way
Singapore Conference Hall
[This Policy was last updated on 29 June 2022]