| 1. |
Introduction |
| 1.1 |
The Verbum Dei Missionary Fraternity (FMVD), Singapore (collectively
referred to herein as "FMVD", "we", "us", and "our") recognises the
importance of personal data entrusted to us. We strongly believe and
are committed to discharging our duty to ensure your personal data
is appropriately managed, protected and processed.
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| 1.2 |
This Data Protection Policy is intended to assist you in
understanding how we collect, use, disclose, protect and process any
personal data that we receive from you and is designed following the
requirements under the Singapore Personal Data Protection Act (2012)
(the "Act" or "PDPA").
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| 1.3 |
This Policy applies to all groups of FMVD. |
| 2. |
Types of personal data collected |
| 2.1 |
"Personal data" generally refers to any data, whether true or not,
about an individual identifiable from the provided data or
information to which we have or are likely to have access and will
include the data from our records, which may be updated
occasionally. Business contact information (e.g. full name, business
address, business telephone number) is not considered personal data
so long as it is used strictly for business-to- business (B2B)
transactions.
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| 2.2 |
The personal data that FMVD may collect about you includes the
following (the list is non-exhaustive):
-
Personal information, such as name, age,
date of birth, religion and birth sex.
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Personal identification information such as
NRIC, FIN, passport number, employment pass, work permit and
other applicable visa or permits.
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Personal contact information such as
telephone numbers, email addresses, and platform user
handles.
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Photographs and video recordings such as
photos taken during services and events, CCTV recordings.
-
Health and medical information, such as
allergies, when necessary for participating in activities or
events.
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| 3. |
Purpose of collecting personal data |
| 3.1 |
The personal data collected will depend on the purpose and needs of
FMVD. We endeavour to only collect, use or disclose personal data
which we consider reasonably necessary for the purposes underlying
such collection, use or disclosure.
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| 3.2 |
FMVD collects personal data for purposes such as those indicated
below (the list is non-exhaustive):
| 3.2.1 |
Events and Activites
-
To register attendance and manage participation
in events and activities such as retreats,
recollections, talks, seminars, conferences,
fundraising, concerts, mission trips,
pilgrimages, etc.
-
To monitor the movement of visitors to our
physical premises for safety and security
purposes.
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| 3.2.2 |
Donations, Giving and Payments for Services
-
To process donations and all types of giving.
- To process payments and refunds.
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| 3.2.3 |
Online Services
-
To administer the dissemination of information
and news through newsletters, articles and the
like.
- To process and manage registrations.
- To respond to requests and queries.
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| 3.2.4 |
Others
-
To process data for statistical analysis and
reporting.
-
To carry out our obligations arising from any
contracts entered into between you and us.
-
To comply with legal obligations and regulatory
requirements.
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| 3.3 |
Where FMVD collects data for purposes other than those listed above,
FMVD will disclose to you such purpose by suitable means.
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| 4. |
Purposes for personal data |
| 4.1 |
All personal data will be used for the purpose it was collected.
FMVD may also use personal data for purposes permitted by law.
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| 4.2 |
Depending on your relationship with us, the Personal Data we gather
from you may be collected, used and disclosed for the following
purposes:
| 4.2.1 |
Administering and managing relationships with FMVD
(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).
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| 4.2.2 |
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.
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| 4.2.3 |
Outreach and engagement to garner support and resources
for FMVD, its community and affiliated institutions.
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| 4.2.4 |
Supporting FMVD functions including, but not restricted
to, the personal and professional development of staff
and administration of FMVD.
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| 4.2.5 |
Engaging participants including but not limited to
notification on FMVD-related initiatives and activities,
invitations to FMVD-related events, updating of
participants’ information, invitation to participate in
participant surveys and sending of communication
collaterals
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| 4.2.6 |
Taking of photographs and videos (whether by FMVD or
third-party photographers and videographers) during
programmes, events or seminars organised by FMVD or its
affiliates for publicity purposes.
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| 4.2.7 |
For record keeping (including and not limited to CCTV
recording at FMVD physical premise).
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| 4.2.8 |
To provide updates on FMVD events. |
| 4.2.9 |
If consented to in the registration form and other
methods of consent notification, providing marketing,
advertising and promotional information via postal mail,
electronic mail, SMS, fax, voice calls and WhatsApp.
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| 4.2.10 |
For any other purposes, which FMVD may inform you of in
writing from time to time, but for which FMVD will seek
your separate consent.
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| 5. |
Disclosure of personal data |
| 5.1 |
We respect the confidentiality of the personal data you provided. In
that regard, we will not disclose your personal data to any third
parties without obtaining your express consent to permit us to do
so.
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| 5.2 |
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:
| 5.2.1 |
Situations in which the disclosure is required based on
the applicable laws and regulations;
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| 5.2.2 |
Situations in which the purpose of such disclosure is
clearly in your interests and consent cannot be obtained
in a timely way;
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| 5.2.3 |
Situations in which the disclosure is necessary to
respond to an emergency that threatens the life, health
or safety of yourself or another individual;
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| 5.2.4 |
There are reasonable grounds to believe that the health
or safety of yourself or another individual will be
seriously affected and consent for the disclosure of the
data cannot be obtained in a timely way, provided that
we shall, as soon as may be practicable, notify you of
the disclosure and the purposes of the disclosure;
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| 5.2.5 |
Situations in which the disclosure is necessary for any
investigation or proceedings;
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| 5.2.6 |
Situations in which 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 functions or duties of the officer; or
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| 5.2.7 |
Situations in which the disclosure is to a public agency
and such disclosure is necessary in the public interest.
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| 5.2.8 |
Where Personal Data is disclosed to third parties with
your express consent, we will provide for adequate forms
of protection over such Personal Data and employ our
best efforts to require such third parties to protect
your Personal Data in compliance with the PDPA and our
data protection policies.
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| 5.3 |
We disclose some of the personal data we have collected about you to
the following parties outside FMVD:
-
Catholic organisations, which are body corporates,
registered societies or otherwise legal entities in their
own right, including the international body of Verbum Dei
Missionary Fraternity.
-
Government agencies such as the Ministry of Manpower, the
Commissioner of Charities, and the Registry of Societies.
-
Providers of professional services such as lawyers, auditors
and relevant entities involved in conducting the activities
or events, such as venue, accommodation or transport
companies.
-
Banks, insurers, payment gateway service providers and other
financial institutions.
-
Third-party service providers such as data processing, cloud
services and web hosting companies.
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| 5.4 |
FMVD may comply with all applicable laws on data protection and
disclose your personal data to third parties, whether located in
Singapore or elsewhere, to carry out the purposes set out above.
Confidentiality agreements exist where FMVD makes such disclosure to
protect personal data.
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| 5.5 |
FMVD may distribute aggregated statistical information to the
Vatican and other Catholic Church agencies for reporting purposes.
In most cases, personal data will be anonymised so no individual
will be identified.
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| 5.6 |
FMVD will NOT disclose personal data for direct marketing purposes
without your consent.
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| 6. |
Obtaining Consent
By providing your personal
data to FMVD, you consent to FMVD's collection, use and disclosure
of your personal data under this Policy
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| 6.1 |
Before collecting, using or disclosing your personal data, FMVD will
notify you of the purposes and obtain your express consent. FMVD
will not collect more personal data than is necessary for the stated
purpose. It will seek your fresh consent if your original purpose
for collecting, using or disclosing your personal data has changed.
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| 6.2 |
Under certain circumstances, FMVD may assume deemed consent from you
when you voluntarily provide your personal data for the stated
purpose, such as when you pose for photos or videos for FMVD.
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| 6.3 |
We may rely on exceptions to the need for consent under the PDPA for
the collection, use or disclosure of your personal data under the
following circumstances:
- The personal data is publicly available.
-
The personal data is disclosed by a public agency or
disclosed to a public agency.
-
The personal data is necessary for any investigation or
proceedings.
-
The personal data is necessary for any evaluative purposes.
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| 6.4 |
Third-Party Consent:
If you have a one-on-one meeting with us, communicate with us in any
form or have a transaction with us on behalf of another individual
(e.g. your spouse, child or family member), you represent and
warrant that the collection, use and disclosure of that personal
data to us, as well as the further processing of that personal data
by us for the purposes set out in this Policy, is lawful.
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| 7. |
Accuracy of information |
| 7.1 |
FMVD strives to ensure the accuracy of our personal data by taking
reasonable precautions and performing verification checks to ensure
that the personal data we have collected from you is reasonably
accurate, complete and up-to-date.
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| 7.2 |
Occasionally, FMVD may do a verification exercise with you to update
you on any changes to your personal data.
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| 7.3 |
However, you must also ensure that the personal data provided is
accurate, relevant and up-to-date. Please see section 8 below for
instructions on how you may correct any errors or omissions of your
personal data.
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| 8. |
Access and Correction of personal data |
| 8.1 |
You may request access to the personal data that FMVD has in our
possession or under our control and how it may have been used and
disclosed by us in the previous year. Before FMVD accepts your
request, we may need to verify your identity by checking your legal
identification document. We will respond to your request as soon as
possible or within 30 days of receiving your request. If we cannot
do so within 30 days, we will let you know and estimate how much
longer we require.
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| 8.2 |
FMVD is entitled to impose a reasonable charge on the requestor for
providing them with personal information, notably where
photocopying, scanning, or some form of electronic transfer is
required.
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| 8.3 |
All access requests must be made in person and written to our email
at verbumdeispore@yahoo.com.sg. Access requests will be directed to
the relevant Data Protection Officer. Please bring along proper
identification documents to confirm your identity.
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| 8.4 |
If you find the personal data FMVD holds about you is inaccurate,
incomplete or not up-to-date, please contact us to correct the data.
Unless FMVD is satisfied on reasonable grounds that a correction
should not be made, we will correct the data as soon as possible or
within 30 days of receiving your request.
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| 9. |
Withdrawal of Consent |
| 9.1 |
If you wish to withdraw your consent to any collection, use or
disclosure of your personal data, you should give FMVD reasonable
advance notice. We will advise on the exact time frame required to
respond to the notification and effect any change. However, all
changes to be effected should be implemented no more than 30 days
from the date of notification.
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| 9.2 |
Your request for withdrawal of consent can take the form of an email
to us at
verbumdeispore@yahoo.com.sg.
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| 10. |
Protection of personal data |
| 10.1 |
FMVD has implemented reasonable and appropriate security measures to
protect the personal data we hold about you against loss, misuse,
destruction, unauthorised alteration/modification, access,
disclosure or similar risks. FMVD has also put in place reasonable
and appropriate organisational measures to maintain the
confidentiality and integrity of your personal data and only share
your data with authorised persons on a 'need to know' basis.
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| 10.2 |
You should be aware, however, that no method of transmission over
the Internet or method of electronic storage is entirely secure.
While security cannot be guaranteed, FMVD strives to protect the
security of your data. It constantly reviews and enhances our
information security measures.
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| 11. |
Retention of personal data |
| 11.1 |
FMVD will only retain the personal data collected for as long as it
is required to fulfil the purposes or allowed by any applicable law
to be retained. It will ensure that personal data no longer needed
will be destroyed or disposed of securely.
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| 11.2 |
Any unsolicited personal data received from individuals will be
assessed to determine whether it is necessary to provide the
individual with the services they requested, and it will be deleted
if found unnecessary.
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| 12. |
Transfer of personal data |
| 12.1 |
FMVD may transfer your personal data outside of Singapore. Where
FMVD does so, we will comply with the PDPA and other applicable data
protection and privacy laws.
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| 13. |
Questions and feedback |
| 13.1 |
If you have any queries about this Policy or feedback regarding
handling personal data, do not hesitate to contact our Data
Protection Officer at the following email address:
verbumdeispore@yahoo.com.sg.
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| 13.2 |
Any query or complaint should include at least the following
details:
- Your full name and contact information
- Brief description of your query or complaint
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| 13.3 |
All feedback is taken seriously and will be reviewed accordingly.
FMVD will endeavour to resolve all raised issues efficiently.
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| 14. |
Links to Other Sites |
| 14.1 |
Our Web Services may contain links to other websites we do not
operate. If you click on a third-party link, you will be directed to
that third-party's website.
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| 14.2 |
You must review the privacy policy of every site you visit. We have
no control over and cannot assume any responsibility for third-party
sites or services' content, privacy policies or practices.
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| 15. |
Changes to the Policy |
| 15.1 |
FMVD may review and update our Policy, procedures and processes
occasionally. It may amend the terms of this Policy at our
discretion. We will post the latest version of our Policy on our
website, which can be viewed at the following web address:
https://verbumdeisingapore.org/privacy-policy. Please revisit this page periodically to ensure you are
well-informed of our latest Policy. Changes to this Policy are
effective when they are posted on this page.
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