Data Protection Company Policy : Purpose & Management

Our Company Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.

With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.

Scope

This policy refers to all parties (employees, job candidates, customers, suppliers etc.) who provide any amount of information to us.

Who is covered under the Data Protection Policy

Employees of our company must follow this policy. Contractors, consultants, partners and any other external entities are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

Why this policy exists

This policy ensures:

  • Complies with the Singapore PDP Act and follow good practice
  • Protects the rights of staff, customers, users and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Policy elements

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs and other volunteering data etc.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

  • Accurate and kept up-to-date
  • Collected fairly and for lawful purposes only
  • Be adequate, relevant and not excessive
  • Processed by the company within its legal and moral boundaries
  • Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

  • Communicated informally
  • Stored for more than a specified amount of time
  • Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities)

In addition to ways of handling the data, the company has direct obligations towards people to whom the data belongs. Specifically we must:

  • Let people know which of their data is collected
  • Inform people about how we’ll process their data
  • Inform people about who has access to their information
  • Have provisions in cases of lost, corrupted or compromised data
  • Allow people to request that we modify, erase, reduce or correct data contained in our databases

Actions

To exercise data protection, we’re committed to:

  • Restrict and monitor access to sensitive data
  • Develop transparent data collection procedures
  • Train employees in online privacy and security measures
  • Build secure networks to protect online data from cyberattacks
  • Establish clear procedures for reporting privacy breaches or data misuse
  • Include contract clauses or communicate statements on how we handle data
  • Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)
  • Our data protection provisions will appear on our website

Disciplinary Consequences

  • All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.

Role of the Data Protection Officer
Zeles Network is a small social enterprise. The Managing Director shall also assume the role as the Data Protection Officer. The responsibilities are:

• Reviewing all data protection procedures and related policies
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data
• Keeping the staff updated about data protection responsibilities, risks and issues
• Arranging data protection sharing and advice for the staff covered by this policy
• Handling data protection questions from staff and anyone else covered by this policy
• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles
• Dealing with requests from individuals to see the data that are being held about them (also called ‘subject access requests’).
• Approving any data protection statements attached to communications such as emails and letters
• Addressing any data protection queries from journalists or media outlets like newspapers

• To disclose requested data of a particular subject to law enforcement agencies, without the consent of the data subject, where the Data Protection Act allows
• Working with the IT Vendor to provide support relating to :

  1. Ensuring all systems, services and equipment used for storing data meet acceptable security standards
  2. Performing regular checks and scans to ensure security hardware and software is functioning properly
  3. Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services

General Staff Guidelines

• The only people able to access data covered by this policy should be those who need it for their work
• Data should not be shared informally. Data when shared are for work purposes only.
• Data Protection good practices shall be shared with all employees to help them understand their responsibilities when handling data
• Employees should keep all data secure, by taking sensible precautions and following the guidelines
• Strong passwords shall be used for accessing the central systems
• Personal data should not be disclosed to unauthorised people, either within the company or externally
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of
• Employees should request help from the data protection officer if they are unsure about any aspect of data protection

Data Storage

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer
  • Data printouts should be shredded and disposed of securely when no longer required

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees
  • Employees should not save copies of personal data to their own computers. All work to be done on the central systems
  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services
  • Servers containing personal data should be sited in a secure location, away from general office space
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones
  • All servers and computers containing data should be protected by approved security software and a firewall

Subject Data Access

All individuals who are the subject of personal data held are entitled to:

  • Ask what information the company holds about them and why
  • Ask how to gain access to it
  • Be informed how to keep it up to date
  • Be informed how the company is meeting its data protection obligations

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at service@zeles.sg. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.