Personal Data Protection Policy
Singapore College of Traditional Chinese Medicine (“SCTCM”) respects the privacy of individuals and recognizes the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect, process and disclose your personal data. We are also committed to adhering to the provisions and principles of the Personal Data Protection Act 2012. As such, this Personal Data Protection Statement is to assist you in understanding how we collect, use and/or disclose your personal data.
We will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2012 (“Act”). The Act establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect or process your personal data, please do not hesitate to contact our Data Protection Officer (“DPO”) at (+65) 6250 3088 or email dpo@singaporetcm.edu.sg.

1. Purpose for the Collection, Use & Disclosure of Personal Data
In general, subject to applicable exceptions permitted in the Act, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain consent for the collection, use and/or disclosure of your personal data for the intended purpose.
Depending on your relationship with us, the personal data which we collect from you may be used and/or disclosed for the following purpose:
For Students:

• General administration of your application and/or registration and/or enquiry for any programme offered by us or our University partners;
• Providing information to relevant government departments/agencies, statutory authorities and industry regulators (such as TCM Practitioners Board, Committee for Private Education);
• Providing the student support and services to you;
• Responding to any complaints, feedback, requests and enquiries by you;
• Disclosing your records to your parent(s) or guardian(s) at their request;
• Informing you of upcoming events, seminars, workshops, conferences and training programmes organised by SCTCM and its affiliated organisations which may be relevant to you;
• Maintaining and updating our student, alumni, and associate lecturer records;
• Generating financial, regulatory, management or survey reports and statistics for SCTCM’s business and administrative purposes;
• Meeting or complying with SCTCM’s internal policies and 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);
• Preventing, detecting and investigating crime, offences or breaches including that related to the security of SCTCM’s premises (including but not limited to the use of security cameras);
• Purposes which are reasonably related to the above.

For Alumnus:

• Maintaining a lifelong relationship with SCTCM alumni;
• Creating awareness and promoting alumni relations; this includes informing you of promotions, benefits and services available to alumni, and organising, facilitating and notifying you of alumni events and programmes, courses or other activities, and providing you with SCTCM publications that are for alumni;
• Studying the profile of the alumni community for SCTCM’s policy making and planning;
• Involving alumni in SCTCM’s continual development and progress through the engagement of voluntary services and giving back to their alma mater.

For Employees/Staff:
In order to comply with its contractual, statutory, and management obligations and responsibilities, SCTCM is required to process personal data relating to its employees including teachers under contract for service. All such data will be processed in accordance with the provisions of the Act and the relevant SCTCM’s rules and policies, including those on data protection, as may be amended from time to time.

• For managing your employment/contract for service relationship with SCTCM;
• For using your bank account details to deposit salaries and other payments;
• For monitoring the use of SCTCM computer network resources;
• For posting your photographs on SCTCM intranet and website, staff pass, newsletters and the like;
• For managing staff benefit schemes;
• Informing you of upcoming events, seminars, workshops, conferences and training programmes organised by SCTCM and its affiliated organisations which may be relevant to you;
• For disclosing your personal data where necessary to Government agencies for official purposes and disclosed to external third parties for, or in connection with, the above purposes, or where required by law;
• Any other purposes not related to those listed above or in your employment contract, which SCTCM may inform you of in writing from time to time, but for which SCTCM will seek your separate consent.

For the Public and Other Third Parties:
SCTCM is committed to engaging and embracing its surrounding community, as well as society at large. We often organise activities in which external stakeholders or the general public are invited to participate, such as seminars, workshops, conferences, training programmes and many others events. Naturally, in encouraging a vibrant interaction with the public, there will be opportunity, and often a need, to collect uses and/or disclose personal data from members of the public. Some of the reasons/ purposes are as follows:

• For security/ verification purposes for certain events;
• For logistical/ administrative purposes for certain events;
• Informing you of upcoming events, seminars, workshops, conferences and training programmes organised by SCTCM and its affiliated organisations which may be relevant to you;
• For marketing/ publicity purposes (e.g. photographs).

For the Prospective, Former, Current Patient or Subject of Medical Research Program:
Besides providing education services, SCTCM also provide TCM medical treatment and research. As such, we will manage and process your personal data in accordance with the requirements of the PDPA, the Ministry of Health's guidelines and directives, and other relevant legislation.

• Administering medical care;
• Providing customer service and support;
• Purposes which are reasonably related to the aforesaid.

For Nominated Caregiver or Next-of-Kin of a patient:

• Informing the patient’s medical status and whereabouts;
• purposes which are reasonably related to the aforesaid.

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2. Disclosure of Personal Data to Third Parties
We will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act. In this respect, please note that we may disclose your personal data to third parties in certain circumstances without first seeking your consent, if such disclosure is either required or permitted under the Act, including without limitation, if the disclosure is required by law and/or regulations or if there is an emergency.

3. Request for Access, Correction and/or Withdrawal of Personal Data
Subject to certain exceptions in the Act, you may request to access and/or correct the personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession at any time by time by submitting your request to the dpo@singaporetcm.edu.sg.
For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such request being made. You may be charged a reasonable fee for the handling and processing of your requests to access your personal data, but you will be notified in advance of such fees.
For a request to correct personal data, we will process your request, including undertaking necessary verification activities, as soon as practicable after the request has been made. We will send the corrected personal data to every other organisation to which the personal data was disclosed by SCTCM within a year before the date of the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose, or if you so consent, only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
For a request to withdraw consent, we will process your request within a reasonable time from such a request being made, upon informing you of the consequences of your request for withdrawal of consent.

4. Administration and Management of Personal Data
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by SCTCM to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also put in place measures such that your personal data in our possession or under our 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.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
Our websites may contain links to other websites not maintained by SCTCM. Such third-party websites are subject to their own data protection and privacy practices and you are encouraged to examine the data protection policies of those websites.

5. Updates on Data Protection Policy
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website.
You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

6. Photography and Recording Notice
Images may be captured during events organised and hosted by SCTCM using film photography, digital photography, video or other medium and may be used on the website, college prospectus or course brochures, other publicity material (such as internal and external newsletters), exhibition of student work or graduation ceremony brochure and may be provided to the media for publication in local or national newspapers or educational magazines.
In this context SCTCM informs all persons taking part in college activities that they may be photographed, filmed, videoed or otherwise captured in image form. Unless express objections are received, individuals attending an event at SCTCM are deemed to have given their consent by attending or remaining at the event. Any queries or complaints should be raised with the college in the first instance.
Updated as at September 2019