This Notice sets out the basis on which Greenwich Management Consultancy Pte Ltd (UEN 201802255M) (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). It applies to personal data in our possession or under our control, including personal data in the possession of organisations we have engaged to collect, use, disclose or process personal data for our purposes.
As used in this Notice, “personal data” means data, whether true or not, about a visitor, job applicant or client who can be identified from that data, or 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, examples of personal data we may collect include:
We collect your personal data when it is provided to us voluntarily by you, or by a third party you have duly authorised to disclose it to us, after you or your authorised representative have been notified of the purposes for which the data is collected and have consented to its collection and use for those purposes; or where collection and use without consent is permitted or required by the PDPA or other laws.
We will seek your consent before collecting any additional personal data, and before using your personal data for a purpose that has not been notified to you, except where permitted or authorised by law. Where personal data is submitted on behalf of a third party, it is the responsibility of the person providing it to ensure the necessary consent has been obtained.
We may collect and use your personal data for any or all of the following purposes:
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 services requested by you; or to third party service providers, agents and other organisations we have engaged to perform any of the functions above.
These purposes may continue to apply even where your relationship with us has been terminated or altered, for a reasonable period thereafter. Where consent is not obtained, we may collect, use or disclose personal data pursuant to an exception under the PDPA.
You have choices regarding our collection, use and disclosure of your personal data. If you choose not to provide the personal data described in this Notice, we may not be in a position to respond to your enquiry, provide the services you have asked for, process a job application, or permit you entry to our premises.
The consent you provide remains valid until you withdraw it in writing. You may withdraw consent and ask us to stop collecting, using or disclosing your personal data for any or all of the purposes above by emailing our Data Protection Officer at admin@greenwich.com.sg.
On receiving your written request we may require reasonable time to process it and to notify you of the consequences, including any legal consequences affecting your rights and liabilities. In general we will seek to process your request within ten (10) business days.
Depending on the nature and scope of your request, we may be unable to continue providing full services to you. We will tell you before completing the processing of your request. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where doing so without consent is permitted or required under applicable law.
You may make an access request for a copy of the personal data we hold about you, or information about the ways we use or disclose it; or a correction request to correct or update any of your personal data. Submit your request in writing to our Data Protection Officer at admin@greenwich.com.sg.
A reasonable fee may be charged for an access request. If so, we will tell you the fee before processing the request.
We will respond as soon as reasonably possible, and in general within thirty (30) days. If we cannot respond within thirty days, we will tell you in writing within those thirty days when we will be able to. If we are unable to provide the personal data or make the correction requested, we will generally tell you why, except where we are not required to do so under the PDPA.
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. These include data protection by design such as minimised collection, authentication and access controls including secure passphrase policies and need-to-know disclosure, encryption of data, up-to-date antivirus protection, regular patching of operating systems and other software, secure erasure of storage media before disposal, and two-factor authentication.
You should be aware, however, that no method of transmission over the Internet or of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect your information and are constantly reviewing and enhancing our information security measures.
We generally rely on the personal data provided by you or your authorised representative. To ensure your personal data is current, complete and accurate, please inform the member of our staff in charge of your account of any changes, in writing or by email, or contact our Data Protection Officer at admin@greenwich.com.sg.
We may retain your personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law. We have established a data retention policy defining retention periods; you may contact our Data Protection Officer to request retention information.
We will cease to retain your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to conclude that retention no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.
We generally do not transfer your personal data to countries outside Singapore. If we do, we will obtain your consent for the transfer and take steps to ensure your personal data continues to receive a standard of protection at least comparable to that provided under the PDPA.
We take the protection of your personal data seriously and have put measures in place to prevent and manage data breaches.
In the event of a personal data breach likely to cause significant harm to individuals, or affecting 500 or more individuals, we will:
We will provide details such as the nature of the breach, the data involved, the actions taken to mitigate risks, and any steps individuals should take to protect themselves.
You may contact our Data Protection Officer at admin@greenwich.com.sg if you have any complaint, enquiry or feedback on our personal data protection policies and procedures, or if you wish to make any request under this Notice.
All complaints and queries will be responded to within 14 business days. Our response will include an explanation of any remedial action taken.
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time. The current version, and the date on which it was last revised, may be obtained on request from our Data Protection Officer. Your continued use of our services after a revised Notice has been provided to you constitutes your acknowledgement and acceptance of the changes.