We at KLC International Institute Pte Ltd (“KLC”) respect the privacy and confidentiality of the personal data of our customers, students, enquirers, service providers and other individuals whom we interact with in the course of providing our products and services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
As used in this Notice:
“Customer” means an individual who (a) has contacted us through any means to find out more about the services we provide, or (b) may, or has, entered into a contract with us for the supply of services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
- COLLECTION OF PERSONAL DATA
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, educational qualifications, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
We collect your information when you
- Register for our various services or attend our events
- Register to visit at our physical premises and your contact information is required for registration and security purposes
- Are within our premises and your images are being captured via CCTV
- Provide us with goods and services as our service providers
- Visit our website and leave behind your contact information
- Provide feedback to us on our products and services or quality of service
We generally do not collect your personal data unless
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- PURPOSE OF PERSONAL DATA COLLECTED
We may collect and use your personal data for any or all of the following purposes:
- Evaluating suitability for admission or employment, enrolling or employing, providing educational courses and training, including sending materials on course / study / assignment / course materials, information on time tables and examination details via postal mail, electronic mail, text messages and/or voice calls;
- Administering and/or managing relationships with the Institute (including responding to enquiries, the mailing of correspondence, statements or notices which could involve the disclosure of certain personal data to bring about delivery of the same);
- Assessing, monitoring and reporting on individual student performance, attendance and disciplinary records;
- Organising curricula and extra-curricular activities including but not limited to outdoor trips and inter-Institute competitions for students;
- Providing pastoral care and counselling where appropriate;
- Application of student passes where appropriate;
- Application for Ministry of Education approval for Singapore Citizens and Permanent Residents;
- Facilitating payment for products and/or services provided by the Institute and/or a third party on the Institute’s behalf including verification of bank and credit card details with third parties and using the Personal Data provided to conduct matching procedures against databases of known fraudulent transactions (maintained by us or third parties);
- Responding to any complaints, feedback, requests and enquiries
- Sending promotional and marketing information by post, email and text messages about the Institute, activities and events as well as carefully selected third parties;
- Taking of photographs and/or videos (whether by the Institute staff or third party photographers and/or videographers) during events or seminars organised by the Institute or its affiliates for publicity purposes;
- Engaging alumni including but not limited to notification on the Institute and alumni- related initiatives and activities, invitation to the Institute and alumni-related events, updating of alumni information, invitation to participate in alumni surveys and sending of communication collaterals;
- Processing applications for and administering local and overseas career related activities, events, programmes, internships, employment opportunities, and career coaching, and sharing information with companies (whether local or overseas) for purposes of recruitment, internship, industrial attachment, job placement and research support;
- Meeting or complying with the Institute’s internal policies and processes / procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
- Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by the Institute, including the obtaining of references and/or other information from prior educational institutions and employers;
- any other purposes for which you have provided the information;
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
- DISCLOSURE OF PERSONAL DATA
Information may be passed to third party organisations or government bodies
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 2 above for us.
- WITHDRAWAL OF CONSENT
You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below in Section 10.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us via email to our Data Protection Officer at the contact details provided below in Section 10.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
- ACCESS TO YOUR PERSONAL DATA
If you wish to request for access to a copy of the personal data which we hold about you or enquiries about the ways in which we use or disclose your personal data, you may submit your request to our Data Protection Officer under Section 10.
- PROTECTING YOUR PERSONAL DATA
We take reasonable steps to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
Notwithstanding the above, you should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure.
- ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided at Section 10.
- RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
We collect information about the pages you view, and the links you click, including advertisements, through common internet technologies such as cookies and web beacons, and your IP-address, which is a number that is automatically assigned to your computer when you use the Internet.
- DATA PROTECTION OFFICER
You may contact our Data Protection Officer at [email protected] if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.
- EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.