This Policy sets out the manner in which BSL Corporate collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 ("PDPA").
This Policy applies to all Individuals (as defined below) who provide BSL Corporate with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by BSL Corporate in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to BSL Corporate, nor does it affect any rights that BSL Corporate may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, BSL Corporate will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide the Personal Data or as required for the purposes of providing services to the Individual or by law.
This Policy does not apply to the following categories of Personal Data:
a) Personal data that is contained in a record that has been in existence for at least 100 years; and
b) Personal data about a deceased Individual who has been dead for more than 10 years.
BSL Corporate may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at www.bslcs.com.sg ("BSL Corporate Website") and appropriate notifications of any material revisions will be published on the BSL Corporate Website and may be issued separately to relevant persons such as may be determined by BSL Corporate. Subject to an Individual's rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with BSL Corporate after any amendments have been introduced and published on the BSL Corporate Website, Individuals shall be deemed to have accepted the Policy as amended.
For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual's specific relationship with BSL Corporate ("Terms and Conditions") and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
BSL Corporate will cease to retain Personal Data after 5 years or as required by the relevant laws and regulations if it is no longer required to fulfil the purpose for which the Personal Data was collected.
Unless otherwise authorised under the PDPA or any other applicable law, BSL Corporate will not collect, use or disclose an Individual's Personal Data without his or her consent.
BSL Corporate will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
Where feasible, BSL Corporate will inform the Individual of purposes that are intrinsic to the relationship between BSL Corporate or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose is intrinsic to the relationship or provision of services, BSL Corporate reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to BSL Corporate's collection, use or disclosure of his or her Personal Data for such purpose.
Individuals who:
will be deemed to agree and consent to BSL Corporate collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Policy.
An Individual who provides BSL Corporate with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to BSL Corporate that he/she has obtained the consent of the relevant third party to BSL Corporate collecting, using or disclosing such Personal Data for the relevant purpose.
In so far as BSL Corporate collects Personal Data of an Individual from any third party, BSL Corporate will take reasonable steps to inform the relevant third party of BSL Corporate's purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party to such disclosure for the intended purpose.
In carrying out one or more of the above Purposes, BSL Corporate may need to disclose an Individual’s Personal Data to the following third parties for one or more of the above Purposes:
Any Individual who wishes to withdraw his or her consent to any use or disclosure of his or her Personal Data by BSL Corporate as set out in this Policy may do so by contacting BSL Corporate’s Personal Data Protection Officer at:
Email address : | PDPA-dpo@bslcs.com.sg |
Mailing address : | BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852 |
Attention : | The Personal Data Protection Officer |
Depending on the extent to which an Individual withdraws consent to the use or disclosure of his or her Personal Data by BSL Corporate, such withdrawal of consent may result in BSL Corporate’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between BSL Corporate and the Individual. BSL Corporate’s legal rights and remedies are expressly reserved in such event.
In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies on his or her internet browser when accessing BSL Corporate’s website. However, this may result in the loss of functionality, restrict the Individual’s use of the website and/or delay or affect the way in which BSL Corporate’s website operates.
Where feasible, BSL Corporate will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to BSL Corporate is complete and accurate. Information voluntarily provided by an Individual to BSL Corporate shall prima facie be deemed complete and accurate.
BSL Corporate will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying BSL Corporate, from time to time, of any applicable changes to such Personal Data.
BSL Corporate shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to BSL Corporate is complete and accurate or who fails to notify BSL Corporate of any relevant changes to such Personal Data.
BSL Corporate may continue to use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual. Individuals who wish to withdraw their consent to BSL Corporate’s use of their Personal Data may contact BSL Corporate’s Personal Data Protection Officer at
Email address : | PDPA-dpo@bslcs.com.sg |
Mailing address : | BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852 |
Attention : | The Personal Data Protection Officer |
BSL Corporate shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If BSL Corporate transfers Personal Data outside Singapore, BSL Corporate will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.
BSL Corporate will ensure that third parties who receive Personal Data from BSL Corporate protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by BSL Corporate, by incorporating appropriate contractual terms in its written agreements with these third parties.
BSL Corporate is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on BSL Corporate’s website.
Any Individual who:
Email address : | PDPA-dpo@bslcs.com.sg |
Mailing address : | BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852 |
Attention : | The Personal Data Protection Officer |
Individuals should note that BSL Corporate is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.
The PDPA allows and BSL Corporate reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.
When a data breach poses risk of impact or harm to the affected Individual, BSL Corporate will as soon as practicable, not later than 48 hours from the time it is aware of the data breach, notify the affected Individual and PDPC. It will inform PDPC if the scale of the data breach is significant, even if the breach does not pose any risk of impact or harm to the affected Individuals.
This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.
Note:
BSL Corporate: BSL Corporate Services Pte Ltd and BSL Advisory Services Pte Ltd.