Revised on: 1 December 2021 (with updated revision to PDPA 2021)
This Privacy Notification sets out the basis which YR Industries Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Privacy Notification applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes. The Privacy Notification is to notify the public (including our clients, and other stakeholders), how we collect, use, disclose the personal data.
YR Industries Pte Ltd is a wholly-owned subsidiary of Yellow Ribbon Singapore that provides laundry and linen management services, food and business solutions, and transitional residential programme. It acts as an intermediary with the Singapore Prison Service to carry out the above-mentioned business activities.
PERSONAL DATA COLLECTION AND ITS USAGE
- As used in this Privacy Notification:“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.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information, financial information and teaching certificate.Our organisation collects the personal data of the respective individual in the following ways:
- Employees: We collect personal details relating to employees such as (a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth; (b) mailing address, telephone numbers, email address and other contact details; (c) employment and training history; (d) salary information and bank account details; (e) details of employee next-of-kin, spouse and other family members; (f) work related health issues and disabilities; (g) records on leave of absence from work; (h) photographs and other audio-visual information; and (i) performance assessments and disciplinary records. We use this personal data to conduct our business, evaluate performance, provide employee benefits, meet our legal obligations as an employee and otherwise manage and administer our employment relationship with our employees.
- Job applicants: We collect personal data provided by job applicants, their referees and via background checks to be used in connection with assessing the applicants for employment opportunities.
- Monitoring of machinery: We may collect personal data through using CCTV cameras to assist with monitoring operation of machinery.
- Residents: We collect personal details relating to residents of Selarang Halfway House (SHWH) such as name, date of birth, emergency contact. If relevant, we will also collect medical records and employment placement details. We will also collect information relating to these individuals that the Singapore Prison Service (SPS) or Yellow Ribbon Singapore (YRSG) decide to provide. This information is used to provide the transitional residential programme activities delivered by SHWH. We also collect information about a resident's participation in these programme activities.
- Customers, supplier and service provider contacts and personnel: We collect contact details of individuals within customer, supplier and service provider organisations so that we can communicate with them about our business activities together. Personnel of some supplier and service provider organisations may work more closely with us. As a result, we may need to collect additional details about those personnel in order to vet them and address applicable building and system access and security requirements. Further, if those personnel need access to prison facilities as part of the engagement with us, then the personnel may need to provide additional details. The details required depend on the security requirements applying at Changi Prison, but
typically include name, NRIC/FIN or passport number, car licence plate.
- Inmate workers: For inmate workers placed with YRI, we collect personal details as directed by YRSG for payroll processing and to undertake activities for the placement arrangement as directed by YRSG.
- Visitors: We collect personal details of visitors to our office premises, SHWH and facilities such as name, date of birth, identity card number and contact number. These details are collected for security purposes.
- Site visits: We collect additional personal details of individuals who apply for a site visit to our linen facility at Changi Prison. The details required depend on the security requirements applying at Changi Prison, but typically include name, NRIC/FIN or passport number, car licence plate.
DISCLOSURE OF PERSONAL DATA
- We may disclose your personal data:
- Customers, suppliers and service providers: We share contact details of our relevant employees with customers, suppliers and service providers in order to conduct our business activities and receive supplies and services necessary for those activities such as IT support. We may also share employee details with providers of employee benefits such as medical benefits to enable the service provider to identify the employee.
- Financial institutions: We share personal data with financial institutions in connection with invoicing of our customers and payments and other benefits to be made to our suppliers and service providers as well as employees.
- Disclosures to YRSG and SPS: We disclose to the SPS details collected for site visits to Changi Prison so they can vet proposed visitors. We are required to disclose to YRSG and the SPS certain personal data relating to inmate workers and SHWH residents.
- Mandatory and permitted disclosures: We share personal data where required under law such as to comply with our obligations as an employer or a legally enforceable demand. We may also share personal data where permitted to under law. We may share personal data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
DEEMED CONSENT BY NOTIFICATION
- We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses 2 and 3. If YR Industries Pte Ltd intends to rely on deemed consent by notification for such secondary purposes, YR Industries Pte Ltd will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.
- In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
- CCTV (Purpose - Security)
- Taking of photos (Purpose - Internal reporting)
- Before relying on deemed consent by notification, YR Industries Pte Ltd will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
- You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
- After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
- In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of YR Industries Pte Ltd or approved intermediary. In relying on the legitimate interests exception of the PDPA, YR Industries Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
- In line with the legitimate interests‘ exception, we will collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and/or
- Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause 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.
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- 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 response to your request within three (3) 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 goods 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 in writing in the manner described in clause 12 above.
- 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 AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). For security reasons, we reserve the right to take steps to authenticate the identity of the requesting party before responding to your query or request.
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
- Minimised collection of personal data;
- Authentication and restricting access controls (such as good password practices, need-to-basis for data disclosure, etc.);
- Data anonymisation;
- Encryption of data;
- Secured LAN, VPN, up-to-date antivirus protection, and other IT security measures with regular review by our IT Service intermediary;
- Deploying physical and technological safeguards to restrict access;
- Secured disposal of personal data after the purpose has ceased; and/or
- Training of our staff to limit Human error that might pose a breach incident.
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 below.
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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.Our current practice is that we do not transfer any personal data outside of Singapore, except in the following limited circumstances:
- Contact details of our personnel may be disclosed to suppliers and prospective suppliers of materials to be used in our business who are located outside of Singapore; and
- If our personnel are travelling outside of Singapore for work, their personal details necessary to make such travel arrangements and booking make be disclosed to relevant parties outside of Singapore.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address : firstname.lastname@example.org
Contact No. : +65 6592-0224
Post: Attention to Data Protection Officer
YR Industries Pte Ltd 27 Loyang Way Singapore 508728
EFFECT OF PRIVACY NOTIFICATION AND CHANGES TO PRIVACY NOTIFICATION
- This Privacy Notification applies in conjunction with any other Privacy Notifications, 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 Privacy Notification from time to time without any prior Privacy Notification. You may determine if any such revision has taken place by referring to the date on which this Privacy Notification was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.