1.1 We at the RHT Governance Risk & Compliance (“We / Us/ Our / Company”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (“Act”) very seriously. We recognise the importance of your personal data that you provide to us and we try to ensure that we properly manage, process and protect your personal data.
1.3 Should you at any time need any clarification on this Policy or our processes, or should you wish to withdraw your consent for us to collect, use and/or disclose your personal information, please feel free to contact the Firm’s Data Protection Officer (“DPO”) whose details are set out later in this Policy.
1.4 We may amend or update this Policy from time to time. Please refer to our website (at www.rhtgr.com) for the latest version.
2. What personal data do we collect?
2.1 What is ‘personal data’?
‘Personal data’ means any information through which an individual may be identified. It may include your name; contact details; NRIC and/or other identification numbers; medical records; photographs and video recording(s) of you attending our talks and seminars; your subscription preferences on our mailing list; your online data when you access our website (including your IP address); any information about you in relation to matters on which you instruct us or in which you are involved; and/or your personal and employment details if you send us your curriculum vitae in connection with employment opportunities with us.
2.2 How do we collect your personal data?
We may collect your personal data in the following manner:
(a) when you provide the personal data to us (e.g. when you contact us via telephone, email or by any other means);
(b) in the ordinary course of our relationship;
(c) when you register for any of our seminars, webinars and events (including signing up to be on our mailing list);
(d) when you visit or use our website;
(e) CCTV recordings while you are within our premises; and/or
(f) when third parties provide it to us.
2.3 For what purpose do we use the personal data?
We may process and/or use the personal data for the following purposes:
(a) conducting regulatory checks and conflict searches; administering and managing our relationship with you, including, without limitation, dealing with any requests or inquiries which you may have and providing services to you (including without limitation, mandatory client due diligence checks and for processing of payments, and following up on unpaid receivables and in legal proceedings to recover receivables);
(b) to respond to your queries, requests and complaints;
(c) conducting research, analysis and development activities (including without limitation, data analytics, surveys and/or profiling) to improve our services and facilities so as to enhance your relationship with us or to improve our services for your benefit;
(d) conducting our recruitment and selection process;
(e) contacting you regarding any updates, events (including seminars and/or webinars) or publications which may be of interest to you;
(f) managing our business and website (including without limitation, storing, hosting and/or backing up of the personal data in and/or outside Singapore);
(g) meeting any legal, governmental or regulatory requirements; and
(h) such other purposes as permitted by applicable law or with your consent.
2.4 Who is responsible for the accuracy of the personal data?
We will take reasonable efforts to ensure that your personal data is accurate and complete, if such personal data is likely to be used by us in order to make a decision affecting you and/or to be disclosed by us to another organisation. This may require that you update us of any changes in your personal data that you have provided to us on any earlier occasion. We will not be liable for relying upon incomplete and/or inaccurate personal data that you have provided to us.
2.5 How will the personal data be protected?
We have established reasonable security arrangements to ensure that your personal data is adequately protected and secured and to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.
Subject to our compliance with the Act and the maximum extent permitted by applicable law, we assume no responsibility for any unauthorised use of your personal data by any third party.
2.6 Who will the personal data be shared with?
All personal data provided to us will be kept safely and shared only on a need-to-know basis. We may disclose your personal data for the foregoing purposes (as set out under clause 2.3 above) to our affiliated entities, third party service providers and agents, other professional advisors and consultants with whom we are dealing on your behalf, any necessary governmental authorities and other third parties including the counsel for an opposing party, whether located in or outside of Singapore, where it is necessary to carry out the purposes set out above.
2.7 Retention of personal data
We have established measures such that your personal data in our possession and/or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
(a) the purpose for which the personal data was collected, is no longer being served by the retention of such personal data; and
(b) retention of personal data is no longer necessary for any other legal, insurance and/or business purposes.
2.8 Transfer of personal data
Where we are required to transfer your personal data out of Singapore for any of the abovementioned purposes, we will ascertain that the standard of protection provided to your personal data is comparable to that under the Act in Singapore.
2.9 Access, Correction & Withdrawal of consent to use personal data
If you wish to:
(a) make a request to obtain a copy of your personal data that is in our possession and/or control; or
(b) make a request for your personal data to be updated or corrected; or
(c) withdraw your consent for us to use or disclose the personal data we hold about you,
please contact our Data Protection Officer to make the relevant request. We may fulfil or reject your request in accordance with the Act.
Please note that if you withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services to you.
Please allow us reasonable time to respond and/or effect any correction.
3. Cookies & Third-Party Links
‘Cookies’ are pieces of information which are issued to your computer and/or mobile device when you visit a website, and which store and track information about your use of the website.
By accessing our website, you agree that we can place cookies on your device.
Our website may contain links to external websites (e.g. LinkedIn). Please note that our Policy does not apply to such external websites and the operations you perform on those websites.
4. Contact Us
If you have any complaint and/or grievance regarding this Policy and/or the terms thereof, please contact our Data Protection Officer (DPO) through one of the methods set out below:
RHT Group of Companies
c/o RHT Management Services Pte Ltd
1 Paya Lebar Link
Paya Lebar Quarter
(Attention – Data Protection Officer)