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PRIVACY POLICY

Introduction

College of Family Physicians Singapore (“CFPS”, “we”, us or “our””) takes the privacy of your (“You, Your, Website and office Visitor, job seekers, CPFS members, students, and member of the public”) information seriously.

Depending on who you are, we may handle your data as a data controller or a data intermediary. Therefore, if you are:

  • A person who visits our office premises, we will may collect your personal data, such as CCTV surveillance footages, as a data controller.
  • A student who attends courses offered and/or organised by us, we may collect your personal information as data controller. In such cases, your personal data may be collected by us and disclosed to third party vendors or vice versa to enable your participation in the courses.
  • A CFPS member may be a person who attends events organised by us as a participant and we may collect your personal information as data controller.
  • A member of the public may be a person who attends events organised by us without being registered as a participant and we may collect your personal information as data controller.

You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in withdrawing clause below (under Withdrawing Your Consent). However, please note that we may not be able to continue with our services including course attendance or to allow you to our office premises, or attend our events, where you have withdrawn your consent for our collection, use or disclosure of your personal data.

We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:

  • To respond to an emergency that threatens your life, health and safety or of another individual;
  • Necessary in the national interest, for any investigation or proceedings.

Personal Data
“Personal data” means data, whether true or not, about a person 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.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, NRIC, gender, age, mailing address, email address, telephone number, audio-video recordings (including CCTV surveillance footages) and still images, and details of your emergency contact person (such as name, relationship and mobile number). Under certain rare circumstances, we may collect data regarding your medical condition, religion, dietary preferences, passport details (such as passport number and issuing country), date of birth, in which case you will be explicitly informed of such data collection.

Other terms used in this Notice shall have the meanings given to them in the Personal Data Protection Act 2012 (PDPA) (where the context so permits).

Information Collection

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).

We may collect and use your personal data for any or all of the following purposes:

  • performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
  • verifying your identity;
  • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
  • managing your relationship with us;
  • 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;
  • any other purposes for which you have provided the information;
  • transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
  • any other incidental business purposes related to or in connection with the above;

Information about User’s computer, including where available User’s IP browser type, operating system, device ID and address, for system administration.

Information about your location such as the country and city you are located in while using this website.

Information that Users provide by sending email through our Contact Us page (https://www.cfps.org.sg/contact-us/contact-information/ ) on the Website. Your e-mail address and name when you contact us.

We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:

  • To respond to an emergency that threatens your life, health and safety or of another individual;
  • Necessary in the national interest, for any investigation or proceedings.

Non-disclosure

CFPS does not sell, release, distribute or lease your Personal data to third parties. CFPS may share data with trusted partners to help us perform statistical analysis, send you email or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to CFPS, and they are required to maintain the confidentiality of your Personal data.

Disclosure of Personal Data

We may disclose your personal data:

  •  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; or 
  • to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.

Reliance on the Legitimate Interests Exception

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of CFPS or another person. In relying on the legitimate interests exception of the PDPA, CFPS will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

  • Fraud detection and prevention; and
  • Detection and prevention of misuse of services.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

Security of Personal Data

We strive to maintain the safety of your Personal Information. We use a reasonable physical and digital security system to store your personal information.

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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.

The implementation of this system is to protect your information from unauthorized access, use, disclosure, or destruction. The information you provide to us may be stored on the secure servers of our trusted service providers, which is located in Singapore and elsewhere.

However, no internet-based service is completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Therefore, by visiting our website, you acknowledge the potential for unauthorized access and agrees to assume the risk.

In the event of a breach that affects your personal information, you will be notified within a reasonable timeframe of such breach and measures we took to rectify the breach. Note that, you may request at any time to access and delete your information with us.

Withdrawing Your Consent

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.

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.

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 above.

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

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.

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.

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) 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). 

Retention time

CFPS retains your personal information for as long as is necessary to fulfil the purpose for which it was collected and whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the CFPS may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, 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.

Accuracy of Personal Data

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.

Transfers of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore, except where the transfer is necessary to fulfil our performance of a contract or where the transfer is necessary for the use or disclosure where exceptions to consent for use or disclosure applies under the PDPA. Where such transfers are made, 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.

Links to Other Websites

Our Website may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own privacy policies.

Singapore Personal Data Protection Act 2012 (“PDPA”)

This section of the Privacy Policy applies only if you are located in Singapore. If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal data, please contact dpo@cfps.org.sg who will review your feedback and respond within 10 business days of receiving it.

Changes to this Privacy Policy

CFPS reserves the right to make changes to this privacy policy at any time. CFPS encourages you to periodically review this Privacy Policy to be informed of how CFPS is protecting your information.

Contact US

CFPS welcomes your comments regarding this Privacy Policy. If you believe that CFPS has not adhered to this Privacy Policy, please contact us at +65 6223 0606 or email: dpo@cfps.org.sg.

Ver: 1.0/ dated: 22 SEP 2023