1. General provisions
    • M-DAQ collects, uses, and discloses personal data from individuals as part of its legal and business purposes, including:
(a) personal data of officers, employees, contractors, consultants, and interns for HR, administrative, and payroll purposes;
(b) personal data of applicants and candidates for hiring purposes; and
(c) personal data of clients’ employees, officers, and shareholders for Due Diligence or compliance with legal or other regulatory purposes.

 

  • Personal data should only be collected, used, disclosed, or retained to the extent necessary for the required purpose.
  • Personal data in electronic form shall be stored on password-secured storage media. Personal data in printed form shall be physically stored in cabinets/drawers.
  • After the required purpose for which the personal data was collected expires or lapses (for example, an employee leaving the company or a client being offboarded), the personal data shall be retained for five (5) years for records purposes before being returned to the individual or disposed.
  • Direct all requests, enquiries, and notices to M-DAQ’s Data Protection Officer:

DPO / dpo@m‑daq.com

  1. Collection, Use, and Disclosure
    • M-DAQ shall not collect, use, or disclose personal data about an individual unless — (a) the individual gives, or is deemed to have given, his consent under the PDPA to the collection, use or disclosure, as the case may be; or (b) the collection, use or disclosure, as the case may be, without the consent of the individual is required or authorised under the PDPA or any other written law.
    • M-DAQ may collect, use, or disclose personal data about an individual without express consent if — (a) the individual voluntarily provides the personal data to M-DAQ for that purpose and it is reasonable that the individual would voluntarily provide the data; or (b) no consent is required in the circumstances set out in the Second, Third, or Fourth Schedules of the PDPA.
    • If express consent is required, M-DAQ may collect, use, or disclose personal data about an individual only for purposes that a reasonable person would consider appropriate in the circumstances and the individual has been notified of the purpose.
  2. Withdrawal of consent
    • An individual may at any time give reasonable notice to M-DAQ to withdraw any consent given, or deemed to have been given under the PDPA, in respect of the collection, use or disclosure by M-DAQ of personal data about the individual for any purpose.
    • On receipt of the notice, M-DAQ shall inform the individual of the likely consequences of withdrawing his consent. M-DAQ shall not prohibit an individual from withdrawing his consent to the collection, use or disclosure of personal data about the individual.
    • Subject to paragraph 1 below, if an individual withdraws consent to the collection, use or disclosure of personal data about the individual by M-DAQ for any purpose, M-DAQ shall cease (and cause its data intermediaries and agents to cease) collecting, using or disclosing the personal data, as the case may be, unless such collection, use or disclosure, as the case may be, without the consent of the individual is required or authorised under the PDPA or other written law.
  3. Accuracy of personal data
    • M-DAQ shall make a reasonable effort to ensure that personal data collected by or on behalf of M-DAQ is accurate and complete, if the personal data — (a) is likely to be used by M-DAQ to make a decision that affects the individual to whom the personal data relates; or (b) is likely to be disclosed by M-DAQ to another organisation.
  4. Protection of personal data
    • M-DAQ shall protect personal data in its possession or under its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
    • Personal data in electronic form shall be stored on devices with secure passwords. Personal data in printed form shall be stored in appropriate filing systems and accessible only by employees of M-DAQ who reasonably require the personal data for legal or business purposes.
  5. Retention of personal data
    • M-DAQ shall cease to retain its documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that — (a) the purpose for which that personal data was collected is no longer being served by retention of the personal data; and (b) retention is no longer necessary for legal or business purposes.
  6. Transfer of personal data outside Singapore
    • M-DAQ shall not transfer any personal data to a country or territory outside Singapore except in accordance with requirements prescribed under the PDPA to ensure that organisations provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
  7. Access and Correction
    • Subject to paragraph 2 below, at the request of an individual, M-DAQ shall, as soon as reasonably possible and in any event within 30 days, subject to the individual paying an administrative fee of US$100, provide the individual with — (a) personal data about the individual that is in the possession or under the control of M‑DAQ; and (b) information about the ways in which the personal data has been or may have been used or disclosed by M-DAQ within a year before the date of the request.
    • M-DAQ is not required to accede to an individual’s request for access to his information in respect of:
(a) opinion data kept solely for an evaluative purpose;
(b) any examination conducted by an education institution, examination scripts and, prior to the release of examination results, examination results;
(c) the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;
(d) personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre;
(e) a document related to a prosecution if all proceedings related to the prosecution have not been completed;
(f) personal data which is subject to legal privilege;
(g) personal data which, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of M-DAQ;
(h) personal data collected, used or disclosed without consent, under paragraph 1(e) of the Second Schedule, paragraph 1(e) of the Third Schedule or paragraph 1(f) of the Fourth Schedule, respectively, for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed;
(i)

the personal data was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he was appointed to act —

(i) under a collective agreement under the Industrial Relations Act (Cap. 136) or by agreement between the parties to the mediation or arbitration;
(ii) under any written law; or
(iii) by a court, arbitral institution or mediation centre; or
(j)

any request —

(i) that would unreasonably interfere with the operations of M-DAQ because of the repetitious or systematic nature of the requests;
(ii) if the burden or expense of providing access would be unreasonable to M-DAQ or disproportionate to the individual’s interests;
(iii) for information that does not exist or cannot be found;
(iv) for information that is trivial;
(v) that is otherwise frivolous or vexatious;
(k)

any request for which the provision of personal data or other information could reasonably be expected to —

(i) threaten the safety or physical or mental health of an individual other than the individual who made the request;
(ii) cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
(iii) reveal personal data about another individual;
(iv) reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
(v) be contrary to the national interest.

 

  • An individual may request M-DAQ to correct an error or omission in the personal data about the individual that is in the possession or under the control of M-DAQ. When M-DAQ is notified of a correction of personal data, M-DAQ shall correct the personal data in its possession or under its control unless M-DAQ is satisfied on reasonable grounds that the correction should not be made.
  • Unless M-DAQ is satisfied on reasonable grounds that a correction should not be made, M-DAQ shall — (a) correct the personal data as soon as practicable; and (b) send the corrected personal data to every other organisation to which the personal data was disclosed by M-DAQ 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.
  1. Data breaches
    • All data breaches shall be immediately reported to M-DAQ’s Data Protection Officer.
    • Upon any data breach, M-DAQ shall take steps to:
(a) contain the breach;
(b) assess the risks and impact;
(c) report the incident by notifying affected individuals, PDPC or other third parties such as banks or law enforcement, where relevant, of any personal data breaches that might cause public concern or whether there is a risk of harm to a group of affected individuals; and
(d) evaluate the response and recovery to prevent future breaches.

 

 

  1.  

 

Definitions

PDPA Personal Data Protection Act 2012 and all Subsidiary Legislation
business contact information means an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes
evaluative purpose

means —

(a)

for the purpose of determining the suitability, eligibility or qualifications of the individual to whom the data relates —

(i) for employment or for appointment to office;
(ii) for promotion in employment or office or for continuance in employment or office;
(iii) for removal from employment or office;
(iv) for admission to an education institution;
(v) for the awarding of contracts, awards, bursaries, scholarships, honours or other similar benefits;
(vi) for selection for an athletic or artistic purpose; or
(vii) for grant of financial or social assistance, or the delivery of appropriate health services, under any scheme administered by a public agency;
(b) for the purpose of determining whether any contract, award, bursary, scholarship, honour or other similar benefit should be continued, modified or cancelled;
(c) for the purpose of deciding whether to insure any individual or property or to continue or renew the insurance of any individual or property; or
(d) for such other similar purposes as may be prescribed by the Minister;
individual means a natural person, whether living or deceased
personal data

means data, whether true or not, about an individual who can be identified —

(a) from that data; or
(b) from that data and other information to which M-DAQ has or is likely to have access;

 

such as “unique identifiers” including —

(a) Full name
(b) NRIC Number or FIN (Foreign Identification Number)
(c) Passport number
(d) Personal mobile telephone number
(e) Facial image of an individual (e.g. in a photograph or video recording)
(f) Voice of an individual (e.g. in a voice recording)
(g) Fingerprint
(h) Iris image
(i) DNA profile
M-DAQ means M-DAQ Pte Ltd, M-DAQ Cashport Pte Ltd, M‑DAQ Financial Services Pte Ltd, and any other organisations within the M-DAQ group

 

 

 

Customer Personal Data Policy

 

This Data Protection Policy (“Policy”) sets out the basis upon which M-DAQ (“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 Policy 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.

By using M-DAQ’s goods or services or continuing your relationship as M-DAQ’s customer or potential customer, you acknowledge that you have read and understood this Policy, and consent to the collection, use and disclosure of your personal data by M-DAQ for the purposes set out in this Policy. You may withdraw consent for such collection, use and disclosure, and make an access or correction request in respect of your personal data, in accordance with this Policy. Given that we may be required by law or other regulatory purposes to collect your personal data, withdrawal of consent may lead to consequences such as termination of our services and our business relationship.

 

  1. Personal data
    • As used in this Policy:
(a) 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 assessing and evaluating your suitability for employment in any current or prospective position within the organisation; and
(b) 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.

 

  • Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
  • Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
  1. Collection, Use, and Disclosure of Personal Data
    • 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:
(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;
(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
(g) 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;
(h) any other purposes for which you have provided the information;
(i) 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
(j) any other incidental business purposes related to or in connection with the above.

 

  • 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 or services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in paragraph 2.2 above for us.

 

  • The purposes listed in the above paragraphs 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).
  1. 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 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 and effect your request within thirty (30) days of receiving it.
    • Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be able 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 paragraph 1 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.
  2. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
    • Please note that you will be charged US$100 for each access request.
    • We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).
    • Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
  3. Protection of personal data
    • 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 the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
    • 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.
  4. 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.
  5. Retention of personal data
    • We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
    • 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
  6. Transfers of personal data outside of Singapore
    • 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 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.
  7. Data Protection Officer
    • 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:

DPO / dpo@m-daq.com

  1. Effect of Policy and changes to Policy
    • This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
    • We may revise this Policy 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 Policy was last updated. Your continued use of our goods and services as a customer or potential customer constitutes your acknowledgement and acceptance of such changes.

 

 

Employment Personal Data Policy

 

This Data Protection Policy (“Policy”) sets out the basis upon which M-DAQ (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees and job applicants in accordance with the Personal Data Protection Act (“PDPA”). This Policy 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.

By continuing your job application or employment with M-DAQ, you acknowledge that you have read and understood this Policy, and consent to the collection, use and disclosure of your personal data by M-DAQ for the purposes set out in this Policy. You may withdraw consent for such collection, use and disclosure, and make an access or correction request in respect of your personal data, in accordance with this Policy. Given that we may be required by law or other regulatory purposes to collect your personal data, withdrawal of consent may lead to consequences such as termination of your job application or employment.

 

  1. Application of this Policy
    • This Policy applies to all persons engaged in a contract of service with us (whether on a part-time, temporary or full-time basis) and interns and trainees working at or attached to us (collectively referred to as “employees”) as well as persons who have applied for any such position with us (“job applicants”), and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).
  2. Collection, Use, and Disclosure of Personal Data
    • We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), 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).
    • If you are a job applicant, your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a) assessing and evaluating your suitability for employment in any current or prospective position within the organisation; and
(b) verifying your identity and the accuracy of your personal details and other information provided.

 

  • If you are an employee, your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a) performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
(b) all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
(c) managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
(d) assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
(e) ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
(f) performing obligations under or in connection with the provision of our goods or services to our clients;
(g) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
(h) facilitating our compliance with any laws, customs and regulations which may be applicable to us.

 

  • The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).
  1. Withdrawing consent by job applicants
    • 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. If you are a job applicant, you may withdraw consent and request us to stop 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 and effect your request within thirty (30) days of receiving it.
    • Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in paragraph 1 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.
  2. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
    • Please note that you will be charged US$100 for each access request.
    • We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).
    • Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
  3. Protection of personal data
    • 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 the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
    • 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.
  4. 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.
  5. Retention of personal data
    • We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
    • 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
  6. Transfers of personal data outside of Singapore
    • 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 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.
  7. Data Protection Officer
    • 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:

DPO / dpo@m-daq.com

  1. Effect of Policy and changes to Policy
    • This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
    • We may revise this Policy 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 employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.