Data Protection Policy
Ngee Ann-Adelaide (NAA) Education Centre respects the privacy of students, alumni, employees and lecturers, be they living or deceased, and recognises the importance of the personal data you have entrusted to us. We are also committed to adhering to the provisions and principles of the Personal Data Protection Act 2012 (“PDPA”). As such, this Personal Data Protection Statement is to assist you in understanding how we collect, use and/or disclose your personal data.
To properly perform the functions of a university and to comply with its legal obligations, we will need to process and keep certain personal data about all individuals with whom it has dealings, including its employees and students.
This policy explains what types of personal data will be gathered and how NAA deals with the personal and other data collected through its website at www.naa.edu.sg.
1. What is Personal Data?
Personal data refers to data about an individual who can be identified from that data whether true or not; or from other info that the organisation has or is likely to have access. It does not include business contact information.
Examples of Personal Data:
• Unique Identifiers: NRIC number, eg. S1234567C
• Set of data which when put together would identify an individual: Name, age, occupation, address, eg. “Mr XYZ, 28 years old, student, lives at Blk 1 Bishan Street 2”
• Personal data may include the following:
|Full Name||NRIC, FIN or Passport number|
|Photograph or video image of an individual||Mobile telephone number|
|Residential telephone number||Name and residential address|
|Personal/ Office email address||Thumbprint for biometric purposes|
2. Collection of Personal Data
2.1 NAA will collect personal data only if the information is necessary for one or more of its functions or activities. It will do so only by lawful and fair means and not in an unreasonably intrusive way. We will not collect excessive or irrelevant information.
2.2 When we collect personal data about an individual from the individual, we will take reasonable steps to ensure that the individual is aware of:
2.2.1 The identity of NAA and how to contact us; and
2.2.2 The fact that he or she is able to gain access to his/her personal data; and
2.2.3 The purposes for which personal data is collected (“primary purpose”); and
2.2.4 To whom (or the types of individuals, organisations or entities to which) NAA usually discloses such personal data; and
2.2.5 Any law that requires the personal data to be collected; and
2.2.6 The main consequences (if any) for the individual if all or part of the personal data is not provided.
2.3 If it is reasonable and practicable to do so, NAA will collect personal data about an individual only from that individual. However, there will be instances where we will obtain such information from other sources, e.g. references for employment purposes; results data for prospective students, verification of formal qualifications of staff and students etc. In such instances, NAA will take reasonable steps to ensure that the individual is or has been made aware of the matters listed in paragraph 3.2, except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual.
2.4 NAA ensures that your Personal Data held by us shall be kept confidential. When transferring personal data to our third party service providers, agents and/or our affiliates or related corporations whether in Singapore or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that your Personal Data disclosed to them is kept confidential and secure.
3. Collection, Use and Disclosure of Personal Data
• Personal data provided online by you will only be used by NAA for the purposes stated when the information is requested (e.g. student administration, provision of services and the dissemination of information to staff, prospective and current students and remaining in contact with graduates, for future communication back to online registrants/enrolees to keep you informed of activities such as campus programmes, symposia and/or special events).
• By furnishing us with your personal information, you agree for NAA to use your name, photograph, quotes and all other such data necessary for the purpose of promoting our academic programmes on various media platforms and/or channels such as on newspapers, websites, brochures, posters, flyers, e-mailers (eDMs), social media like Facebook, LinkedIn and Instagram), as well as others deemed suitable and/or appropriate.
• NAA will not disclose your personal data without your consent unless otherwise required or authorised by law.
• If you choose to send an application or email containing personal data, NAA may, in order to process the application or to render you a service, share relevant personal data within NAA and/or if necessary, with the Ministry of Education and other government agencies or statutory bodies or non-government agencies authorised to carry out specific government services and duties, unless such sharing is prohibited by the Act or other legislation.
• Personal data will not be sold to third parties, or provided to direct marketing companies or other such organisations without your consent
• Information about your visit to the NAA website may also be logged to provide NAA with de-identified statistical analysis about users’ online experiences and trends as well as the popularity and effectiveness of NAA’s website and troubleshooting purposes.
• NAA may disclose your personal data to a third party (e.g. your family or medical or security personnel) if the disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or that of another person.
4. Accuracy and Access of Personal Data
4.1 As NAA relies on your Personal Data to provide services to you, you shall ensure that at all times the information provided by you to us are correct, accurate and complete. Student shall update us in a timely manner of all changes to the information provided to us through the Student Services Centre. Alumni and lecturers shall update their Personal Data to our relevant departments as and when necessary or through our annual update.
4.2 You can view your personal data which NAA has collected and stored at any time. In order to do so, you will need to submit the request for access for personal data to the relevant departments for access to view your personal data. Your right to view your personal data is limited to your personal data only. NAA is not permitted to reveal any personal data about any other individual. NAA reserves the right to refuse access to your personal data if it will reveal or lead to the revelation of another individual’s personal data, cause harm to you or another individual or is contrary to the national interest.
5. Protection and Retention of Personal Data
5.1 Personal data provided by you will ordinarily be stored on NAA’s secure servers. However, NAA may work with third party service providers to host and/or operate certain features of the website. NAA will take all steps reasonably necessary to ensure that your personal data held by such third party service providers will be kept, used and disclosed in accordance with this policy.
5.2 We will take commercially reasonable steps to destroy or permanently de-identify personal data if it is no longer needed for any purpose. Destruction of personal data will be carried out in accordance with NAA’s prevailing policies and procedures for records retention and management.
6. Transfer of Personal Data
NAA will only transfer personal data about an individual to someone or an entity (other than NAA or the individual) who is outside Singapore if:
• 6.1.1. NAA reasonably believes that the recipient of the personal data is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the personal data that are substantially similar to the principles set out in this policy; or
• 6.1.2 the transfer is necessary for the performance of a contract between the individual and NAA, or for the implementation of pre-contractual measures taken in response to the individual’s request; or
• NAA has taken reasonable steps to ensure that the personal data which it has transferred will not be held, used or disclosed by the recipient of the personal data inconsistently with this policy.
7. Updates to this Policy
7.1 NAA reserves the right to amend this Policy with or without notice from time to time.
If you have any feedback or enquiries relating to our PDPA related policies and procedures or would like to obtain access and make corrections to your personal data, please do not hesitate to contact our Data Protection Officer at firstname.lastname@example.org.