1.1 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified –
(a) from that data; or
(b) from that data and other information which an organisation has or is likely to have access.
Such Personal Data shall also refer to that which is already in the possession of Aptitude Career Solutions or that which shall be collected by Aptitude Career Solutions in future.
1.2 This Policy provides information on the obligations and policies of Aptitude Career Solutions in respect of an individual customer’s Personal Data. Aptitude Career Solutions undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out in this Policy to its operations.
1.3 Aptitude Career Solutions and its representatives (including its management, staff, financial consultants, etc.) shall use reasonable endeavours to respect the confidentiality of and keep safe all Personal Data collected, stored, disclosed and used for, or on behalf of, the Organisation. Aptitude Career Solutions shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by the Organisation shall be done in an appropriate manner and in accordance to the Act and this Policy.
1.4 Aptitude Career Solutions and its representatives (including its management, staff, financial consultants, etc.) shall use reasonable endeavours to respect the confidentiality of and keep safe all Personal Data collected, stored, disclosed and used for, or on behalf of, the Organisation. Aptitude Career Solutions shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by the Organisation shall be done in an appropriate manner and in accordance to the Act and this Policy.
1.5 This Policy supplements but neither supersedes nor replaces any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
2 Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Aptitude Career Solutions, we shall provide and/or correct that data in a reasonable time and manner in accordance with our standard procedures as stated in this Policy.
2.2 In accordance with the Personal Data Protection Act, Aptitude Career Solutions has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Aptitude Career Solutions receives your complaints and enquiries, please send the same via email or post to the Data Protection Officer (the “DPO”), of Aptitude Career Solutions:
Email address: email@example.com
2.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a client via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Aptitude Career Solutions on your behalf.
2.4 Should you choose to withdraw consent previously given to Aptitude Career Solutions to use your Personal Data for any of the purposes listed in Paragraphs 3.2, or choose not to receive promotional materials from Aptitude Career Solutions, you may opt out by sending a clearly worded email or mail to the DPO via the email or post address provided in Paragraph 2.2 above. Your request shall be processed within 30 days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
3 Statement of Practices
Types of Personal Data Collected
3.1 As part of its day-to-day activities, Aptitude Career Solutions may collect from data subjects, through various means, including via referrals, introducers, road shows, seminars, personal networks and social media, and any forms (survey forms, feedback forms) used by the Organisation from time to time, the following Personal Data:
- Full name
- NRIC/Passport number
- Date of birth
- Marital status
- Residential address
- Phone number (including mobile)
- Email address
- Employment status
- Income details
- Education level
- Dependants’ details
- Bank account/credit card details
- Photographs and images
- Other information, as may be required in the respective forms.
Purpose of Collection of Personal Data
3.2 In order to carry out the functions described below, Aptitude Career Solutions requires consent to collect and use your Personal Data. Failure to receive consent may affect our ability to provide solutions to you. The Personal Data mentioned in Paragraph 3.1 is collected for the following purposes:
Disclosure of Personal Data
3.3 In order to carry out the functions described above, Aptitude Career Solutions may, from time to time, disclose your Personal Data between its Organisational entities.
3.4 Aptitude Career Solutions may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
- To the extent that the Organisation is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend the Organisation’s legal rights;
- To any person and/or entity for the purpose of processing such information on the Organisation’s behalf;
- To third parties who provide services to the Organisation or on its behalf;
- With your consent; or
- For the purposes of disaster recovery.
Optional Provision of Personal Data
3.5 Under certain circumstances, telephone calls made to any of Aptitude Career Solutions’ service hotlines or inquiry telephone numbers will be recorded for the purposes of training, quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
4 Transfer of Personal Data Overseas
4.1 Your Personal Data may be processed by Aptitude Career Solutions’ affiliates, agents, introducers and third parties providing services to organisations in jurisdictions outside of Singapore. The Organisation will comply with the terms of the Personal Data Protection Act in such events.
5 Transfer of Personal Data Overseas
5.1 Where possible, Aptitude Career Solutions will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Aptitude Career Solutions is able to validate the data provided against pre-existing data held by the Organisation. In some cases, Aptitude Career Solutions is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of the Organisation, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email or post address provided at Paragraph 2.2.
6 Protection of Personal Data
6.1 Aptitude Career Solutions uses commercially reasonable physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside the Organisation, other than to you or as described in this Policy. However, Aptitude Career Solutions cannot ensure or warrant the security of any information you transmit to us should there be any breach of the safeguards or any situation which is beyond Aptitude Career Solutions’ control at the information transmission stage. In particular, Aptitude Career Solutions cannot warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of the Organisation’s physical, technical or managerial safeguards.
7 Access and Correction of Personal Data
7.1 In accordance with Paragraph 2.1 of this Policy, you have the right to:
(a) check whether the Organisation holds any Personal Data relating to you and, if so, obtain copies of such data; and
(b) require the Organisation to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 Aptitude Career Solutions reserves the right to charge a reasonable administrative fee in order to meet your requests under Paragraph 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.
7.3 If you wish to verify the details you have submitted to Aptitude Career Solutions or if you wish to check on the manner in which the Organisation uses and processes your personal data, our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, contact number and NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which Aptitude Career Solutions takes in response to a request from someone using your details.
8 Storage and Retention of Personal Data
8.1 Aptitude Career Solutions will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of the Organisation and where the Personal Data is deleted from the Organisation’s electronic, manual, and other filing systems in accordance with the Organisation’s internal procedures and/or other agreements.
9 Contacting you
9.1 To the extent that any of the communication means which you have provided Aptitude Career Solutions with (which may include your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing of the Your Financial Blueprint, or by any other means of indication, you hereby grant Aptitude Career Solutions your clear and unambiguous consent to contact you using all of your communication means you have provided to the Organisation, including via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated in Paragraph 3.2.
10 Change of Policy
10.1 Aptitude Career Solutions reserves the right to alter any of the clauses contained in this Policy in compliance with local legislation, and for any other purpose deemed reasonably necessary by the Organisation. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11 Governing Law
11.1 This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by Aptitude Career Solutions. It does not cover third-party sites to which we provide links. Aptitude Career Solutions does not share your Personal Data with third-party websites. Aptitude Career Solutions is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.