Personal Data Protection Policy
Monochrome Learning Solutions (“MCLS”) collects personal data to support its teaching, learning, research, administration, personal development, to process applications for admission of candidates to MCLS and for other functions in line with the operational requirements of a training agency.
MCLS’s Personal Data Protection Policy (“Policy”) discloses how MCLS collects, uses, access, stores, transfers and handles your personal data, in accordance with the Personal Data Protection Act 2012 (Act 26 of 2012) (“Act”). By providing your personal data to MCLS, you are consenting to this Policy and the collection, use, access, storage, transfer and processing of your personal information by MCLS and its respective representatives and/or agents as described in this Policy.
This Data Protection Policy supplements but does not supersede nor replace any consent you may have previously provided to MCLS in respect of your Personal Data, and your consents are in addition to any rights which to any MCLS and/or its respective representatives and/or agents may have by law to collect, use or disclose your Personal Data with or without your consent.
1. Personal Data
“Personal Data” refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information, which an organization has or is likely to have access.
Such Personal Data includes, but is not limited to, your name, gender, date of birth, passport or other identification number, telephone number(s), residential mailing address, personal email address, photographs, video recordings or CCTV footage from which you can be identified, and any other personal information or details that you provide to MCLS.
2. Purposes for the Collection, Use and Disclosure of Personal Data
Such Personal Data will be collected, used, disclosed, transferred and/or processed by MCLS for the following purposes: –
- Processing, administering and/or managing your relationship, admission and enrolment with MCLS;
- For your use of any online services available at any of MCLS’s or partner’s websites and/or through other telecommunication channels;
- Facilitating or managing any business transaction(s) with you;
- When you interact with our officers, employees, authorised agents via telephone calls, mail, in-person meetings, email and any other forms of communication;
- For identification and verification purposes in connection with any of the services or courses that may be supplied to you by MCLS or partners;
- Carrying out due diligence or other screening activities in accordance with the law or regulatory requirements or risk management procedures that may have been put in place by MCLS, including conducting background checks or obtaining of references and/or other information about applicants from previous employers or education institution(s);
- Responding to any of your enquiries;
- To disclose to partners for the purposes of managing or delivering a training programme;
- Investigating fraud, misconduct, any unlawful action or omissions and whether or not there is any suspicions of the aforementioned;
- Responding to requests for information from the Government, public agencies, ministries, statutory boards or other similar authorities from time to time;
- Carrying out market-related or similar research and analysis for MCLS’s operational strategy and policy planning purposes;
- Organising graduations, student welcome ceremonies or other promotional or student-related events;
- For legal purposes (including but not limited to obtaining external legal advice and dispute resolution proceedings);
- With consent, sending you marketing, advertising, and promotional information, including materials and information on courses in MCLS or partners, student-related activities and/or other events via postal mail, email, SMS, fax, voice calls, digital communication or other forms of communication;
- Through attending the training, sharing sessions, talks and other events, you consent to the use of your photograph, voice, likeness, and image in any broadcasts of this event and in subsequent productions drawn from video or audio recordings of such activities. The photographs and recordings may be published or broadcasted in the official MCLS website and affiliates’ publications and in publicity materials, including the MCLS affiliates’ websites and social media platforms. All recordings, articles, quotes, photographs, films, audio or video and/or any reproductions of same in any form, are the property of MCLS. MCLS, its affiliates, employees, representatives and agents are released from any and all claims, demands, costs and liability that may arise from the use of these interviews, recordings, photographs, videotapes or films, and/or any reproductions of same in any form, as described above, arising out of being interviewed, recorded, photographed, videotaped or filmed. It is the responsibility of participants to remove themselves from group and candid shots/recordings that the photographers/videographers intend to capture, if they do not wish to have their photos/audio-visual recordings taken at such activities.
- Any other additional purpose that is consistent with the original purpose for which consent was given; and
- When you submit your Personal Data to us for any other reasons.
Such Personal Data may be disclosed by MCLS to our partners, third party service providers or agents (whether in Singapore or elsewhere in the world where such service providers are sited) for one or more of the above purposes, as such third party service providers or agents, if engaged by MCLS, would be proceMCLSng your Personal Data for MCLS, for one or more of the above purposes.
3. Withdrawal of Consent
If you would like to withdraw your consent to any use of your Personal Data as set out in this Policy, please fill in the Withdrawal of Consent Form and send it to the Data Protection Officer.
Please note that when you withdraw your consent to any use of your Personal Data as set out in this Policy, it may affect the services provided by MCLS or partners when such consent is regarded as a condition of providing services from MCLS or its partners.
If you would like to access your Personal Data, which we collect, use, disclose and/or process, please fill in the Access to Personal Data Request Form and send it the Data Protection Officer.
We may charge an access fee at the point of request to cover the reasonable cost of retrieving the information and supplying it to you as permitted under the Act.
Access to personal data may be refused if access to such information could reasonably be expected to cause harm to an individual’s safety; reveal the identity of another individual who has provided the personal data but has not consented to the disclosure of his or her identity; or be contrary to national interest.
5. Accuracy and Correction
MCLS makes reasonable efforts to ensure that the Personal Data it collects is accurate and complete. To assist MCLS in keeping its records up-to-date, it is important that you inform MCLS of any changes to your Personal Data in writing. If you would like to correct any inaccuracies of your Personal Data, please fill in the Correction of Personal Data Request Form and send it to the Data Protection Officer.
6. Security of Personal Data
MCLS has reasonable security arrangements in place to protect the Personal Data that it possesses to prevent unauthorized access, collection, use, disclosure or similar risks. Please take note that no computer, electronic or data storage system is immune from intrusion and therefore, we cannot guarantee the absolute security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter MCLS’s websites (for example viruses, bugs, Trojan horses, spyware or adware). You are advised to take note of the risks and implement the necessary precautions.
7. Transfer of Personal Data
MCLS has in place reasonable measures to ensure that transfer of Personal Data out of the jurisdiction is protected and in compliance with the Personal Data Protection Act.
8. Retention of Personal Data
MCLS will retain your Personal Data for a reasonable period for the purposes for which it was processed or until you request for MCLS to delete the Personal Data, or as required by law.
9. Personal Data Protection Officer
Should you have any questions, feedback or concerns relating to MCLS’s Personal Data Protection policies or wish to access, correct or withdraw any consent relating to your personal data, please contact our Data Protection Officer:-
Email address: email@example.com
Postal address: Attn: Data Protection Officer, 519 Balestier Road, #02-04, Singapore 329852
Please include the following information for verification purposes:-
- Your full name and NRIC or Passport number;
- A clear photocopy of your NRIC or Passport;
- Your contact details;
- Name of the officer or employee by whom your personal data was collected; and
- Details of your request.
By providing to us with complete information, we will be able to provide you access to, update or correct your personal data as soon as reasonably poMCLSble.
For more information on how MCLS handles complaints pertaining to Personal Data, please refer to MCLS’s Personal Data Protection Complaints Procedure.