Speech Lab Privacy Policy
1.0 Introduction
Your privacy is important to us. This Speech Lab Pte. Ltd. (“SLPL”) Personal Data Protection Policy sets out how SLPL complies with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”). We recognise 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 Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
2.0 Introduction to Personal Data Protection Act
“Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include names, NRIC, FIN or Passport number, contact information, medical records, thumbprint, photographs and video images.
SLPL will collect your personal data in accordance with the PDPA. In general, before we collect any personal data from you, we will notify you of the purposes 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.
3.0 Purposes for Collection, Use & Disclosure of Personal Data
Depending on your relationship with SLPL (e.g. as an applicant, student, parent, guardian, staff, vendor, service provider, or other person relating to our organisation), the personal data which we collect from you may be collected, used and/or disclosed for the following purposes:
Evaluating suitability for admission or employment, enrolling or employing, providing educational services and teaching, including sending materials on course / study / assignment / study notes, information on time tables and examination details via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
Administering and/or managing relationships with SLPL (including responding to enquiries, the mailing of correspondence, statements or notices which could involve the disclosure of certain personal data to bring about delivery of the same);
Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by SLPL, including the obtaining of references and/or other information from prior educational institutions and employers;
Responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorised to carry out specific Government services or duties;
Carrying out market-related, evaluative or similar research and analysis for SLPL’s operational strategy and policy planning purposes, including providing data to external parties for school programme evaluation;
Processing, administering and conferring awards of prizes, medals, scholarships and other marks of distinction and the publication or releasing of information on the same;
Taking of photographs and/or videos (whether by SLPL staff or third-party photographers and/or videographers) during events or seminars organised by SLPL or its affiliates for publicity purposes;
If consented to in the registration form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
Any other purposes which SLPL may inform you of in writing from time to time, but for which SLPL will seek your separate consent.
In order to conduct our operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates, which may be sited locally or outside of Singapore, for one or more of the above-stated purposes. Such third party service providers, agents and/or affiliates would be processing your personal data on our behalf for one or more of the above-stated purposes.
4.0 Specific Issues for the Disclosure of Personal Data to Third Parties
We respect the confidentiality of the personal data you have provided to us. In that regard, we will not disclose any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
the disclosure is required based on the applicable laws and/or regulations;
the purpose of such disclosure is clearly in your interests and consent cannot be obtained in a timely way;
the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
the disclosure is necessary for any official investigation or proceedings;
the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement 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; and/or;
the disclosure is to a public agency and such disclosure is necessary in the public interest.
The instances listed above are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012.
In all other instances of disclosure of personal data to third parties with your express consent, we will provide for adequate forms of protection over such personal data and confidentiality and security in the handling and administration of your personal data by such third parties in compliance with the PDPA and our data protection policies.
5.0 Third-Party Sites and Digital Services
This Data Protection Policy applies only to SLPL systems and websites. Our websites and digital services may contain links to other websites not maintained by SLPL. Such third party websites and digital services are subject to their own data protection and privacy practices and you are encouraged to examine the privacy policies of those websites and services. SLPL is not responsible on the content and privacy practices of these other digital services and we encourage you to consult the privacy notices of those digital services.
6.0 Request for Access, Correction and/or Withdrawal of Personal Data
For a request to access personal data, we will:
provide you with the relevant personal data within a reasonable time from such a request being made.process your request, including undertaking necessary verification activities, as soon as practicable after the request has been made. We will send the corrected personal data to every other organisation to which the personal data was disclosed by SLPL 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, or if you so consent, only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made. We may also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct your personal data, but you will be notified in advance of such costs.
For a request to withdraw consent, we will process your request within a reasonable time from such a request for withdrawal of consent being made. Requests for withdrawal of consent may adversely impact your relationship with SLPL. We will notify you in advance of such impacts.
7.0 Administration of Personal Data
We will take appropriate measures to keep your personal data accurate, complete and updated.
We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
(i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data and
(ii) retention is no longer necessary for any other legal or business purposes.
8.0 Retention of Your Personal Data
We will retain your Personal Data for as long as they are required to fulfill the purposes mentioned above, or as required by applicable laws.
9.0 Updates on Data Protection Policy
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. We may amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and shared on relevant platforms.