Privacy Policy

1 Introduction

At Singapore Corporate Services Pte. Ltd. (hereinafter referred to as “SCS” or the “Company”), we respect the privacy and confidentiality of the personal data of our Clients, Associates, and others with whom we interact in the course of providing our 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, relevant laws, sectoral, and international guidelines.

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.

2 How We Collect Your Personal Data

Personal data refers to any information that can uniquely identify an individual person, either (a) on its own or (b) when combined with other information. Under the PDPA, business contact information (e.g., full name, business address, business telephone number) is not considered as personal data as long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data when you:

Enter into business-to-business transactions with us, such as engaging our corporate secretarial, tax, or outsourced accounting services; and
Enter into an employment contract or apply for a job position with us.

3 Types of Personal Data We Collect About You

The types of personal data we collect about you include:

Your contact information (Name, Address, Phone Number, Email Address)
Your personal details (Name, Gender, Date of Birth, Country of Birth, Country of Residence, Citizenship, Nationality, Race/Ethnicity)
Personal and professional details contained in your curriculum vitae when you apply for a job with us.

4 How We Use Your Personal Data

We use the personal data you provide to us for one or more of the following purposes:

Performing obligations in the course of or in connection with our provision of the services requested by you;
Verifying your identity for due diligence checks in accordance with sectoral laws;
Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
Managing your relationship with us;
Sending information about our services, including notifying you of our events and initiatives;
Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any government and/or regulatory authority;
Any other purposes for which you have provided the information;
Transmitting to any unaffiliated third parties, including our third-party service providers and agents, and relevant government and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
Any other incidental business purposes related to or in connection with the above.

5 Who We Disclose Your Personal Data To

We disclose some of the personal data you provide to us to the following entities or organisations outside SCS in order to fulfil our services to you:

Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
To third-party service providers, agents, and other organisations we have engaged to perform any of the functions listed in clause 4 above on our behalf.

Where required by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6 How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use, or disclose your personal data, we will notify you of the purpose for which we are doing so. We will obtain written confirmation from you regarding your expressed consent. We will not collect more personal data than is necessary for the stated purpose, and we will seek fresh consent from you if the original purpose for the collection, use, or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, for example, when you apply for a job with us using our job application forms.

We may rely on exceptions to the need for consent under the PDPA for the collection, use, or disclosure of your personal data under the following circumstances (only those relevant to SCS are included):

The personal data is publicly available.
The personal data is disclosed by a public agency or disclosed to a public agency.
The personal data is necessary for any investigation or proceedings.
The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for).
The personal data is necessary for the purpose of managing or terminating an employment relationship.
The personal data is necessary for a business asset transaction.
The personal data is required to comply with a law or regulation.

6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent within working 7 days of your withdrawal request, e.g. without your consent, we may not be able to fulfil our obligations to you as a service provider and/ or employer.

Your request for withdrawal of consent can take the form of an email or letter to us.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website and stored on your computer to enable the website to recognise you and keep track of your preferences. The cookie makes your experience more convenient, as it eliminates the need to retype the same information when you revisit the website or fill in electronic forms.

Most of the cookies we use are “session cookies,” which are automatically deleted from the hard disk of your computer at the end of your session.

You have the option to choose not to accept cookies by disabling this feature in your web browser. Please note that doing so may prevent you from using some of the features and functions in our web applications.

6.4 Third-Party Consent

If you conduct a transaction with us on behalf of another individual that requires you to provide that individual’s personal data to us, you must ensure that this individual has given his/her expressed consent for you to provide his/her personal data to us. We will require you to obtain written confirmation from this individual, verifying that he/she has indeed given their expressed consent to you, allowing us to collect, use, or disclose his/her personal data.

7 How We Ensure The Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading, and kept up-to-date.

From time to time, we may conduct a data verification exercise to allow you to update us on any changes to the personal data we hold about you. If we have an ongoing relationship with you, it is important that you inform us of any changes to your personal data, such as a change in your mailing address.

8 How We Protect Your Personal Data

We have implemented appropriate information security and technical measures, such as data encryption, firewalls, and secure network protocols, to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration, modification, access, disclosure; or similar risks.

We have also established reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data. We will only share your data with authorised individuals on a “need-to-know” basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us by implementing the necessary organisational and technical security measures, and taking reasonable steps to comply with these measures.

9 How We Retain Your Personal Data

We have a document retention policy that tracks the retention schedules of the personal data you provide to us, whether in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10 How You Can Access and Make Corrections to Your Personal Data

You may write to us to inquire about how we have been using or disclosing your personal data over the past year. Before we fulfill your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, typically within 30 days from the date we receive it. If, for any reason, we are unable to do so within the 30 days, we will inform you and provide an estimate of the additional time required. Please note that we may charge a reasonable fee for processing your access request. If you choose not to agree to the fee, we may regrettably be unable to process your request. In such cases, you are welcome to seek further clarification or discuss alternatives with our Data Protection Officer (DPO).

If you discover that the personal data we hold about you is inaccurate, incomplete, misleading, or not up-to-date, you may request us to correct it. If we are satisfied, based on reasonable grounds, that a correction is necessary, we will make the correction as soon as possible, typically within 30 days from the date we receive your request.

11 Transfer of Personal Data

When there is a need to transfer your personal data to another country outside of Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If it is not comparable, we will enter into a contractual agreement with the receiving party to provide similar levels of data protection as those in Singapore.

12 Contacting Us

If you have any queries or feedback regarding this Policy, or any complaints related to how we manage your personal data, you may contact our Data Protection Officer (DPO) at dpo@scs-cpa.com.

For unsolicited personal data that you may receive, please contact our DPO and delete it accordingly.

Any query or complaint should include, at a minimum, the following details:

Your full name and contact information.
A brief description of your query or complaint.

We take such queries and feedback seriously and will handle them confidentially and within a reasonable timeframe.

13 Changes to This Data Protection Notice

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to stay informed of any updates.

Changes to this Notice take effect when they are posted on our website.

Updated on 29 May 2021