DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which MEDLINK SERVICES PTE LTD (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers 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.
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as nric, fin, work permit, residential address, email address, telephone number, nationality, gender and date of birth, employment information.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions; and
(f) 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.
(g) any other purposes for which you have provided the information; and
(h) Any other incidental business purposes related to or in connection with the above.
6. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
WITHDRAWING YOUR CONSENT
7. 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 in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
8. 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.
9. 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 goods or 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 writing in the manner described in clause 7 above.
10. 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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
11. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. 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.
13. We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days 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).
PROTECTION OF PERSONAL DATA
14. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and use of privacy filters.
15. 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.
ACCURACY OF PERSONAL DATA
16. We generally rely on personal data provided by you (or your authorised representative). 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 in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
17. 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.
18. 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
19. 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.
DATA PROTECTION OFFICER
20. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : MR. KEVIN SHOFF
Contact No. : 6909 3202
Email Address : [email protected]
EFFECT OF NOTICE AND CHANGES TO NOTICE
21. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
22. 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.
Effective date : 12/12/2019
Last updated : 12/12/2019
DEFINITION OF WHISTLE-BLOWING
Whistle-blowing is the disclosure of information which relates to suspected wrongdoings or dangers at work. It includes criminal activities, corruption, bribery, financial fraud, danger to workplace health and safety, failure to comply with legal obligations or regulations, breach of Company policies and Code of Conduct, unauthorised disclosure of confidential information, etc. It also includes any deliberate attempt to cover up any of the activities mentioned above.
A grievance is a matter of personal interest and does not impact the wider public. Whistle-blowing deals with more serious concerns which is of public interest. When the matter affects a larger group of people and/or the nature of the wrongdoing is more serious, the matter can generally be said to be of public interest.
The objectives of the policy are:
- To provide a formal process to raise and handle whistle-blowing concerns.
- To encourage employees and other stakeholders to report improper, unethical and inappropriate behaviour.
- To provide assurance that all reports will be properly addressed and treated with confidentiality.
This policy applies to all individuals working for or engaged with Medlink Services Pte Ltd and its products or services. This means that it applies to full-time staff, part-time staff, contractors, freelance trainers, consultants, customers and other stakeholders.
WHY “BLOW THE WHISTLE”
Employees and customers of Medlink Services Pte Ltd are the eyes and ears of the Company. The findings of the investigation may be essential to the growth, reputation and performance, of the Company and could even save people from harm or death.
The Company encourages whistle-blowers to identify themselves when raising a concern to the Whistle-blowing Governance Officer who by default is the Managing Director. Should there be a disclosure relating to the Managing Director, the Whistle-blowing Governance Officer will be a member of senior management.
We do not encourage anonymous disclosures. Proper investigation may be more difficult or impossible if we cannot obtain further information from the whistle-blower. It is also more difficult to establish whether any allegations made are credible. The Company assures all whistle-blowers that proper and appropriate measures will be taken to preserve confidentiality. The Whistle-blowing Governance Officer will seek the whistle-blower’s consent if his/her identity needs to be disclosed to a third party. To assist us in maintaining confidentiality, it is also important for whistle-blowers to practice discretion and refrain from discussing the matter with any other party.
Whistle-blowers who raise concerns and/or complaints are helping the company to address critical issues. The Company assures that the whistle-blower will not face detrimental treatment or adverse consequences for utilising this policy if done so in a matter of good faith. Raising concerns in good faith means that a genuine attempt has been made to provide honest and accurate information, even if proven to be mistaken after investigation.
Similarly, employees should continue to treat whistle-blowers in a courteous and respectful manner and should not engage in behaviour that might alienate or intimidate them. If any employee feels that he/she have been retaliated against because of whistle-blowing, he/she should report this behaviour to the Human Resource Department (HR) immediately. Disciplinary actions will be taken against those who retaliate, harass or discriminate against whistle-blowers.
This protection extends to anyone giving information in relation to an investigation.
HOW TO CONTACT US
Whistle-blowers may use any of the available channels mentioned below to report their
- Fill up the Whistle-blowing Form online at https://bit.ly/2yfeK94
- Call +65 6909 3202
- Set an appointment to meet with the Whistle-blowing Governance Officer at: Rehau Building 1 King George’s Avenue #04-00 Singapore 208557
WHAT TO REPORT
- Your name (as mentioned above, we do not encourage anonymity for investigation purposes)
- Contact Number/Email Address
- Details of alleged misconduct or activity occurred
- Information of personnel involved
- Time, date and location of alleged activity
- Evidence of alleged activity (if any)
Should the whistle-blower decide to include his/her name and contact details, an appointed investigator may request for a meeting to gather and document all the information needed to understand the situation.
The parties involved in the investigation would be determined by the investigator depending on the nature, extent, timeline and complexity of the case. Some possible parties may include the whistle-blower, alleged party, witnesses, key staff, management and external parties.
The investigation process comprises establishing the investigation objective, gathering of evidence, reporting on the findings and providing recommendations. Due to the varied nature of these sorts of disclosure, it is not possible to lay down precise timescales for such investigations. The investigator should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.
The Whistle-blowing Officer will aim to get back to the whistle-blower with general feedback about the disclosure as soon as the investigation is concluded.
In cases where there are no grounds for the concern, the Whistle-blowing Governance Officer (or a designated staff) will inform the whistle-blower of the outcome and close the case. Where there is ground for the concern, HR will design and implement the disciplinary/ remedial measures, which should be both practical and feasible. Where there may be grounds for a possible criminal offence, management will be informed and legal advice may be sought on whether the matter should be referred to the relevant authority for the appropriate action. The whistle-blower will be notified if reporting to external parties are made.
Anonymous whistle-blowers will not ordinarily be able to receive feedback and any action taken to look into a disclosure will be limited.
POLICY COMMUNICATION DISSEMINATION & REVIEW
This whistle-blowing policy is communicated and disseminated to employees during the company’s induction process. It is also accessible to all interested parties at the company website. The company supports the training of staff involved in whistle-blowing to stay abreast of developments and to be properly equipped to handle whistle-blowing matters.
This policy will be reviewed on an annual basis by the Whistle-blowing Governance Officer or HR. Employees should approach HR or the Whistle-blowing Governance Officer for assistance on whistle-blowing matters.
Effective Date: 1 st February 2020
Last Updated: 21 st April 2020