It is Skool4Kidz Pte Ltd (“Skool4Kidz”)’s policy to comply with all applicable primary and data protection laws in accordance with the Singapore’s Personal Data Protection Act 2012 (“PDPA”). Skool4Kidz recognises the importance of safeguarding personal data that parents and/or guardians and their children, and relevant public (collectively referred to as “the Public”) have entrusted to the organization. It is Skool4Kidz’s responsibility to properly manage, protect and process personal data.
Should the Public at any time, have any queries relating to personal data, they may contact Skool4Kidz’s Data Protection Officer (“DPO”).
Introduction to the PDPA
- “Personal Data” as defined under the PDPA refers to data collected, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organisation has or is likely to have access.
- The Public will be notified of the purposes that personal data is collected, used, disclosed and/or processed and obtain consent, unless an exception under the law permits that no prior consent is needed by Skool4Kidz to collect and process personal data.
Purposes for collection, use, disclosure and processing of personal data
You may be requested to provide personal data such as, but not limited to, the following, depending on your request:
- Full name;
- Residential address;
- Identity card number;
- Payment details, such as credit card and banking information;
- Contact details, such as telephone number or email address;
The above personal data which Skool4Kidz collects may be used, disclosed and/or processed for:
- To complying with any law or the requirements of any regulatory authority;
- To update the customer on our products and services;
- Assessing the Public’s suitability for programme enrolment;
- For the daily operation of the services;
- Facilitating student-related and/or enrolment related matters such as tracking and managing attendance and academic performances, application and renewal of student passes;
- Providing information and/or updates related to Skool4Kidz’s programmes, products and services, marketing campaigns, promotions, benefits, and events by SMS, phone, email, fax, mail, website, social media and/or any other appropriate communication channels;
- Administering and processing of any payments, fee adjustments, insurance claims, refunds and waivers related to programmes, products, services and/or trainings requested;
- Responding to any feedback, enquiries, requests or complaints and resolve any issues and disputes which may arise from any relationships with Skool4Kidz;
- Conducting market research or surveys on Skool4Kidz’s programmes, products and/or services;
- Processing of royalty payments, referral payments and commission fees to Skool4Kidz’s business and corporate partners;
- Sharing of personal data with Skool4Kidz’s business or corporate partners for development of programmes, products and/or services or launch marketing campaigns;
- Sharing of personal data with financial institutions for processing of payment instructions, debt recovery, applying and obtaining credit facilities;
- Maintaining and updating of school records;
- Audit, risk managements and security purposes;
- Detecting, investigating and preventing fraudulent, prohibited or illegal activities and analysing and managing of commercial risk;
- Enabling Skool4Kidz to perform its obligations, transfer, assign and enforce rights, interests and obligations under any agreements or documents that the company is a party of or entered into;
- Meeting or complying with any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to Skool4Kidz;
- Enforcing or defending Skool4Kidz and the Public’s rights, and to comply with obligations under the applicable laws, legislations and regulations; and/or
- Other purposes which Skool4Kidz notifies at the time of obtaining the Public’s consent; and/or any purpose which are reasonably related to the aforesaid
(Collectively referred to as “Purposes”).
As the Purposes for which Skool4Kidz may or will collect, use, disclose or process the Public’s personal data depends on the circumstances at hand, such purpose may not appear above. However, Skool4Kidz will notify the Public of such other purposes at the time of obtaining consent, unless processing of personal data without consent is permitted by the PDPA or by law.
Specific issues for the disclosure of personal data to third parties
Skool4Kidz respects the confidentiality of the personal data the Public has provided. Skool4Kidz will not disclose the Public’s personal data to third parties without first obtaining consent to do so. However, there are situations that Skool4Kidz may disclose the Public’s personal data to third parties without first obtaining the Public’s consent including, without limitation, the following:
- Cases in which disclosure is required or authorised based on the applicable laws and/or regulations;
- Cases in which the purpose of such disclosure is clearly in the Public’s interests, and if consent cannot be obtained in a timely way;
- Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of the Public or another individual;
- Cases in which the disclosure is necessary for any investigation or proceedings;
- Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- Cases in which the disclosure is to a public agency and such disclosure is necessary in the Public’s interests;
- Associated organisations or affiliates controlled by, or under common control with Skool4Kidz
- Financial institutions, charge or credit card issuing companies, credit bureau, or collection agencies necessary to establish and support the payment of any services being requested; and/or
- Where such disclosure without the Public’s consent is permitted by the PDPA or by law.
The instances listed above are not intended to be exhaustive. For more information, please visit https://sso.agc.gov.sg/
In the event where by Skool4Kidz discloses the Public’s personal data to third parties with the Public’s consent, Skool4Kidz will employ the best efforts to safeguard the Public’s personal data.
Access and correction
The Public may request to update access, change or remove any information the personal data in Skool4Kidz’s records by submitting a written request to the DPO at firstname.lastname@example.org.
For a request to update personal data, once Skool4Kidz has sufficient information from the Public, Skool4Kidz will:
- Skool4Kidz will notify the Public of the soonest practicable time within which correction can be made. (Note: The PDPA exempts certain types of personal data from being subject to the Public’s correction request as well as provides for situations when correction need not be made by Skool4Kidz despite the Public’s request); and
- Send the corrected personal data to organisations to which the personal data was disclosed by Skool4Kidz within a year before the date the correction was made, unless the other organisation does not need the corrected personal data for any legal business purpose.
- Skool4Kidz may, if the Public gives consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by Skool4Kidz within a year before the date the correction was made.
Request to withdraw consent
Skool4Kidz will process the Public’s request within seven (7) working days from the date the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose the Public’s personal data. All requests not to use personal data for marketing and promotional purposes will be honoured.
However, the Public’s withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that Skool4Kidz will not be able to continue with the existing relationship with the Public and the contract that the Public has with Skool4Kidz will have to be terminated.
The Public may withdraw their consent for the collection, use and/or disclosure of their personal data by submitting their request to Skool4Kidz’s DPO at email@example.com.
Management of data (Accuracy, Completeness, Protection and Retention)
Skool4Kidz will take reasonable efforts to ensure that the Public’s personal data is accurate, complete and up-to-date. Skool4Kidz will not be responsible for relying on inaccurate or incomplete data arising from the Public not updating Skool4Kidz of any changes in their personal data that was initially provided.
Skool4Kidz will also put in place reasonable physical, technical and administrative security measures to ensure that all personal data is adequately protected and secured. However, Skool4Kidz cannot assume responsibility for any unauthorised use of the Public’s personal data by third parties.
Skool4Kidz will also put in place measures such that the Public’s personal data in Skool4Kidz’s possession or under Skool4Kidz’s control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
If the Public’s personal data is to be transferred out of Singapore, Skool4Kidz will comply with the PDPA in doing so. Skool4Kidz will also take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the Act.
The Public may contact Skool4Kidz’s DPO through email or letter if they have any complaints or grievances with regard to the handling of personal data or Skool4Kidz’s compliance with the PDPA.
Updates on data protection policy
As part of Skool4Kidz’s efforts to ensure that Skool4Kidz properly manages, protects and processes the Public’s personal data, Skool4Kidz will review the policies, procedures and processes from time to time.
Skool4Kidz reserves the right to amend the terms set forth under this Data Protection Policy at Skool4Kidz’s absolute discretion. All amended Data Protection Policy will be posted on Skool4Kidz’s website.
The Public is encouraged to visit Skool4Kidz’s website from time to time to ensure that they are well informed of Skool4Kidz’s latest policies in relation to personal data protection.
Email correspondences may contain privileged / confidential information. If the email is not intended for the recipient, he must not copy, distribute or use it for any purpose, nor disclose its contents to any other person. The recipient is to notify the sender immediately if the email is received in error.
Data Protection Officer
Skool4Kidz Pte Ltd
87 Marine Parade Central, #03-208
For more information, read the full Early Childhood Development Centres Act here: https://sso.agc.gov.sg/SL/ECDCA2017-S890-2018?DocDate=20190214