KWAN IM THONG HOOD CHO TEMPLE

DATA PROTECTION POLICY FOR COUNSELLING SERVICE CLIENTS

This document (“Document”) sets out the basis on which the KWAN IM THONG HOOD CHO TEMPLE (“the Temple”) may collect, use, disclose or otherwise process personal data of a counselling service client in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Document applies to personal data in the Temple’s possession or under its control.

The Temple will comply with the relevant laws in Singapore relating to data protection and data management.

DEFINITIONS

“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 the Temple has or is likely to have access;

“counselling service client” means a person who has previously sought counselling, is currently seeking, applying for or undergoing counselling, or has in the past undergone counselling by the Temple’s counselling service; and

“authorised agent” means a person who has represented to the Temple that he or she has been duly authorised by a counselling service client to disclose the said counselling service client’s personal data to the Temple.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

1. The Temple generally does not collect personal data of a counselling service client unless it is provided to the Temple voluntarily by the said counselling service client or an authorised agent.
2. Unless consent is deemed to have been provided to the Temple for the collection of personal data, the Temple will generally not collect personal data of a counselling service client unless (i) the said counselling service client has been notified of the purposes for which the personal data is collected, and (ii) the said counselling service client has consented to the collection and usage of his or her personal data for those purposes.
3. The above clauses do not apply if collection and use of personal data without consent is permitted or required by the PDPA or any other written law.
4. The Temple may collect and use a counselling service client’s personal data for any reasonable purpose in relation to the application for or provision of counselling, including but not limited to any and all of the following purposes:
1. establishing or managing the counselling service client’s relationship with the Temple;
2. processing and evaluating the counselling service client’s application for counselling;
3. verification of the counselling service client’s identity;
4. provision of counselling and any ancillary or related services to the counselling service client;
5. monitoring, evaluating and/or auditing of services provided to the counselling service client, including but not limited to an assessment of the quality of the services provided and the effects of the services provided (both in the short and long term, and even after the counselling service client has stopped using such services;
6. providing the counselling service client with information on the Temple’s (or another organisation’s) upcoming events or activities where the Temple reasonably believes that the counselling service client may benefit from attending such events or activities;
7. responding to, handling, and processing queries, requests, applications, complaints and feedback from the counselling service client;
8. 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; and
9. transmitting to any unaffiliated third parties including the Temple’s 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 purposes related to or in connection with the above.
5. The Temple may disclose a counselling service client’s personal data:
1. where such disclosure is required for, or in connection with, the provision of the services requested by the counselling service client;
2. to third party service providers, agents and other organisations the Temple has engaged to perform any of the purposes listed above;
3. to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations;
4. to any other party to whom the counselling service client has authorised the Temple to disclose such personal data to, or where necessary to undertake any action requested by the counselling service client; and
5. in any circumstances which the client has consented to.
6. The purposes listed in the above clauses may continue to apply even in situations where the counselling service client’s relationship with the Temple has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable the Temple to enforce its rights against the counselling service client.

WITHDRAWING CONSENT

7. The consent that a counselling service client provides for the collection, use and disclosure of his or her personal data will remain valid until such time as it is withdrawn by the said counselling service client in writing. A counselling service client may withdraw consent and request the Temple to stop collecting, using and/or disclosing his or her personal data for any or all of the purposes listed above by submitting such request via email or otherwise in writing to the Temple’s Data Protection Officer at the contact details provided below.
8. Upon receipt of a counselling service client’s written request to withdraw consent, the Temple may require reasonable time (depending on the complexity of the request and its impact on the Temple’s relationship with the said counselling service client) for such a request to be processed and for the Temple to notify the said counselling service client of the likely consequences of such withdrawal of consent. In general, the Temple will seek to process such requests within fourteen (14) days of receiving the same.
9. Whilst the Temple respects a counselling service client’s decision to withdraw consent, the Temple will not be in a position to continue providing counselling or other services to the said counselling service client.
10. Withdrawing consent does not affect the Temple’s right or obligation to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

11. If a counselling service client wishes to make (i) an access request for access to a copy of the personal data about him or her which is in the possession of or under the control of the Temple or information about the ways in which the Temple has or may have used or disclosed such personal data within a year before the date of the request, or (ii) a correction request to correct an error or omission in the personal data about him or her which is in the possession of or under the control of the Temple, he or she may submit such a request via email or otherwise in writing, to the Temple’s Data Protection Officer at the contact details provided below.
12. A reasonable fee may be charged for an access request, and the person requesting the information will be informed of the estimated fee before the processing of the request.
13. The Temple will respond to a request for access or correction within a reasonable period. In general, a response will be sent to the requestor within thirty (30) days. Requests for access to and/or correction of personal data will be dealt with in accordance with the provisions of the PDPA.

PROTECTION OF PERSONAL DATA

14. To safeguard counselling service clients’ personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, the Temple has taken appropriate and reasonable administrative, physical and technical measures.
15. However, counselling service clients must be aware and accept that no method of transmission over the Internet or method of electronic storage is completely secure and that the possibility of leakage of information always exists regardless of the extent of precautions taken, and consent to the collection, use and storage of personal data by the Temple includes an acceptance of such risk.

ACCURACY OF PERSONAL DATA

16. The Temple relies on the accuracy of personal data provided by counselling service clients for the provision of counselling as well as any ancillary or related services, and inaccurate data may affect the quality of such services provided, and counselling service clients are responsible for informing the Temple of any changes in their personal data.

RETENTION OF PERSONAL DATA

17. The Temple may retain a counselling service client’s 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. The Temple will cease to retain a counselling service client’s personal data if 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. The Temple generally does not knowingly transfer personal data to countries outside of Singapore and will not do so except in compliance with the provisions of the PDPA.

CLOSED-CIRCUIT TELEVISION (“CCTV”) SYSTEMS

20. The Temple operates CCTV systems in its premises, and any visitor to the premises may be recorded. The CCTV systems are installed for security and to protect both visitors and staff. CCTV footage will be viewed when necessary and is stored on a temporary basis, other than where it has been flagged for review.

AUDIO AND VIDEO RECORDING

21. The Temple may conduct audio and video recordings to aid in counselling and any ancillary or related services or training sessions.
22. The Temple will obtain a counselling service client’s consent before any recording is made of him or her during a counselling (or ancillary or related services) session.
23. Unless permission is given, such recordings will be deleted after review.

DATA PROTECTION OFFICER

24. Counselling service clients may contact the Temple’s Data Protection Officer if they have any enquiries or feedback on the Temple’s personal data protection policies and procedures, or if they wish to make any request, in the following manner:

Head Counselling Service (Data Protection Officer)

Address: #11-01, 108 Robinson Road, Singapore 068900

Email Address: counselling@kwanim.org

EFFECT OF DOCUMENT AND CHANGES TO DOCUMENT

25. This Document applies in conjunction with any other documents and notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of a counselling service client’s personal data by the Temple.
26. The Temple may revise this Document from time to time without any prior notice. A counselling service client may determine if any such revision has taken place by referring to the date on which this Document was last updated. A counselling service client’s continued use of the Temple’s services constitutes his or her acknowledgement and acceptance of such changes.