PERSONAL DATA PROTECTION POLICY
Respecting your privacy and protecting your personal data
The SIM Group of companies 1 (SIM) and our affiliates, respects your privacy and recognizes the importance of data protection.
In the course of your dealing with us, we may be required to collect and use your personal data – such as in providing services to you, when you register or participate in a programme, course or activity, or through any other engagements with us, as summarised in the sections below.
In this statement which covers all entities under SIM, we would like to share how we process your personal data strictly for legitimate business purposes and in accordance with the Personal Data Protection Act ("PDPA").
"Personal data" is data or a set of data which when put together, would identify an individual. Personal data may be in digital or non-digital forms and may include full name, national identification number, personal mobile number and email address, voice and/or image recording (such as CCTV, photograph and audio/video recording), age, credit card number, residential address and phone number. It does not include business contact information
To "process" means to collect, use, store, transfer, disclose, alter, correct, delete or destroy personal data.
To find out more about PDPA, you may visit the Singapore Personal Data Protection Commission’s website.
What personal data do we collect
The amount and type of personal data we collect from you will be limited to what is necessary, reasonable, lawful and for identified purposes. They may include the following (non-exhaustive list):
- Full name
- National identification number
- Home address
- Contact number (residential and mobile)
- Email address
- Facial image (ID photo, video, CCTV recording, etc.)
- Date of birth
- Bank account details, credit card number
- Next of kin personal details (name, relationship, contact numbers for emergencies)
- Past academic achievements, results/transcripts, other assessment details and/or qualifications
- Past employment information and/or curriculum vitae
- Any other types of personal data indicated in our data collection forms, for which the appropriate purposes(s) will be made known to you
We will seek your consent before collecting additional data or using your data for a purpose which has not been indicated to you, except where permitted by law.
How we use your personal data
We may use your personal data:
- to comply with applicable laws, regulations and/or requirements from government bodies regulatory authorities, and/or other relevant bodies
- to fulfil legitimate business interests and/or contractual and legal obligations
- for improving and enhancing our products and services, and innovation
- for the purposes below, depending on your engagement with us, and/or purposes separately communicated to you
(“Learners” in this statement includes prospective students, students, participants of seminars/training courses/events
and all applicants
- for assessing admission and enrolment, and performing administration, delivery and awarding of certifications and/or qualifications for programmes, as required by university and/or training partners, and/or any relevant regulatory bodies
- for administration and conduct of Continuing Educating and Training (CET) programmes, events and/or career or skills conversion programmes to meet the learning needs of organisations and individuals.
- for management and conduct of co-curricular and/or supporting programmes, where applicable, for holistic development
- for provision of ancillary support and services such as financial assistance, sponsorship, grant, bursary, scholarship and/or other awards, library and other supporting services.
(“Alumni” in this statement includes all former students
as described earlier.)
Employees / Job Applicants
- for staying connected and fostering relations
- for organizing of and invitations to events and initiatives
- for sending communication collaterals and publications
- for providing support and services including informing you of latest promotions, benefits and learning programmes and services available for your continuous learning journey
(“Employees” under PDPA guidance and in this statement, refers to all persons engaged with us - whether on a temporary, part/full-time or contract basis – including lecturers, trainers, consultants, associates, staff, interns, trainees, volunteers
and all applicants
- for assessing suitability for employment and/or engagement within SIM, including placement with our subsidiaries
- for purposes related to your employment or other contract
- for purposes related to the provision of services to our university partners, collaborating organisations, affiliates and/or clients.
- for conducting centralised operations and services more efficiently, such as library services, online platforms and services, financial and payment matters, audit matters and/or other general administration
- for gathering and responding to feedback, enquiries, surveys and/or other data analysis to improve our products and services, policies and planning
- for providing personalized offers or sending marketing materials with your consent
- for carrying out safety and security measures such as closed-circuit television (CCTV), protection against unauthorized access or usage of our physical or IT platforms, investigating any fraudulent activities and conducting checks and audits
- for news, publicity, training and educational purposes, through the use of your photographs, videos and/or audio recordings taken at events, classes or other activities
For any other purpose not related to what is indicated in this statement or in any contract with us, we will seek your separate consent in writing where applicable.
Who we share your personal data with
We may share your personal data within SIM, with our approved third-party service providers, university partners and/or organisations and affiliates, and relevant regulatory bodies for the purposes mentioned above.
We may use and disclose your personal data without consent as permitted under statutory exemptions, such as when:
- required by law; or is necessary for any investigation or proceedings
- necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual
Transfer of personal data outside Singapore
Generally, we do not transfer personal data out of Singapore except under collaboration with university partners and/or organisations and our approved third-party service providers for applicable services. Should we do so, we will ensure there is data protection of a standard that is at least comparable to that under the PDPA.
How we protect your personal data
We understand the importance of protecting your personal data and deploy appropriate security and technological measures to safeguard your data.
How long do we keep your personal data
We retain your personal data for as long as necessary to fulfil the purposes for which they were collected, for business or legal purposes, or as required or permitted under law.
When we no longer need your personal data, we will delete or destroy it securely.
How to withdraw consent, access, update or correct your personal data
We respect your rights to your personal data. Please complete the "Contact Us regarding your Personal Data" form and we will respond as follow:
- Withdrawal of consent – within 10 working days upon receiving your request.
- Access, update or correct your personal data – within 30 calendar days upon receiving your request.
For current Student and Associate Lecturer, please login to your respective dedicated portals directly.
To process your request, we will seek to verify your identity and other details so as to retrieve the relevant data. If we are unable to complete your request we will inform you of the reasons.
In responding to your access request, we may collect a reasonable fee if necessary and will inform you beforehand. We may also require a reasonable ground, such as a police report in order to access CCTV data, which we will inform you prior to processing your request.
Email Marketing Communications
You can choose to opt-out from our email marketing communications at any time using the “unsubscribe” links provided in the email marketing communications sent to you. Please note that opting out of email marketing communications does imply the withdrawal of consent of personal data used for other purposes, such as engaging in services with us.
Cookies and other ad-tracking technologies
When you visit and use the services on our websites, we may collect information from your browser using tracking technologies (such as cookies, web beacons, tracking pixels etc.) These tracking technologies help us understand how the site is used and enable us to enhance your browsing experience on our website.
We may collect information from your browser including but not limited to information such as IP address, browsing behaviour and preferences. Tracking is anonymous and no personal information is collected. You may choose to decline cookies in your browser setting; however, this may affect your web experience.
If you are below 13 years old, you must obtain your parent/guardian’s consent before providing your data to us, unless under exceptions and/or provisions of other relevant acts and regulations. We may request for evidence of parental/guardian’s consent obtained before processing your personal data.
Updates to this policy
This policy applies in conjunction with any other relevant policies, notices, contractual and consent clauses entered with us.
To ensure relevancy, we may update this policy from time to time, without prior notice. Please visit this website for the latest version which will always be published.
For any queries or feedback regarding this policy, please contact us using the "Contact Us regarding your Personal Data" form or email our Data Protection Officer at firstname.lastname@example.org .
The SIM Group of companies (SIM) includes Singapore Institute of Management Group Limited, Singapore Institute of Management Pte Ltd and SIM AEC Pte Ltd which offer programmes and services under the key brands SIM Global Education and SIM Professional Development and Enterprise Learning.
Last updated: 23 July 2021