(Version: 5 March 2023)

True Way Presbyterian Church – English Congregation (“TWPC-EC”, “we”, “us” or “our”) is a constituent member of the Presbyterian Church in Singapore. It is independently established and registered as a society under the Societies Act (Cap. 311) and is one of two congregations worshipping at the premises of True Way Presbyterian Church (“Church”) at Stirling Road, Queenstown.

TWPC-EC committed to protecting the personal data and privacy of individuals who provide such data to us. In general, we collect, use, disclose and care for personal data in accordance with the Personal Data Protection Act 2012, regulations made under the PDPA (collectively, “PDPA”) and other applicable laws. This Data Protection Policy (“Policy”) provides information as to how we may handle your personal data while meeting the requirements of the PDPA.

Unless otherwise stated, this Policy applies in conjunction with any other data protection notice, policy or terms and conditions which we may publish or give to you from time to time, for example, prior to or upon collection of your personal data, prior to our using your personal data for a purpose or in any form or document in which you provide your personal data to us.

This Policy may be reviewed and amended by us from time to time. Please refer to our website (https://truewaypc.com/DP-Policy) for the latest version of this Policy.

Queries relating to this Policy, and any request or complaint relating to your personal data, may be sent to in writing, via post or email to:

Data Protection Officer
True Way Presbyterian Church – English Congregation
156B Stirling Road, Singapore 148947
Email: [email protected]

For more about the PDPA and data protection in general, you may wish to visit the website of the Personal Data Protection Commission (www.pdpc.gov.sg).

 

1. PERSONAL DATA COLLECTED, USED AND DISCLOSED BY TWPC-EC

1.1      In this Policy (and generally as referred to by TWPC-EC), “personal data” means any data (information) about an identifiable individual (natural person). Data relates to an identifiable individual if the individual can be identified from that data, whether alone or in combination with other information that TWPC-EC has access to.

1.2      Personal data which TWPC-EC may collect, use and disclose (for the purposes specified in paragraph 2) includes (but is not limited to) the following:

(a)       Personal identification details such as name, NRIC number, FIN and passport number;

(b)       Personal biographical information such as date of birth, age, nationality, gender, marital status and names of family members attending the Church;

(c)       Personal contact information such as residential address, telephone number and email address;

(d)       Financial information, for example, relating to payments or donations made to TWPC-EC or payments / honoraria made by TWPC-EC to individuals;

(e)       Personal information relating to your pastoral care needs and/or those of your family members;

(f)        (For members of TWPC-EC) Information which may relate to your life as a Christian and/or as a member of TWPC-EC, such as dates and places of baptism, confirmation and marriage;

(g)       (For prospective employees) Information relating to your employment history (such as previous employers and positions/titles), academic qualifications, employment pass / work permit information and information provided by past employers and referees; and

(h)       Images and audio recordings (e.g. in photographs and video recordings), including (but not limited to) (i) recordings made by CCTV cameras at the premises of the Church and (ii) photographs and video recordings taken at locations or events which are open to the public.

1.3      This Policy and the relevant parts of the PDPA generally do not apply in respect of business contact information obtained by TWPC-EC which is not provided to us for purely personal purposes (such as the business contact information of another organisation’s employees).

 

2. BASES AND PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

TWPC-EC may collect and use your personal data or disclose your personal data to another person or organisation in the following situations (as further described in the PDPA):

(a)       with your consent, obtained prior to or upon collection of your personal data or otherwise prior to using your personal data for a purpose;

(b)       with your deemed consent, that is, where you voluntarily provide the personal data to us for a purpose;

(c)       where the PDPA or any other written law permits the collection, use, and/or disclosure of your personal data without your consent;

(d)       where the collection, use and/or disclosure of the personal data is in the vital interests of an individual;

(e)       where the personal data is publicly available or the collection, use and/or disclosure of personal data relates to matters affecting the public or is in the public interest;

(f)        where the collection, use and/or disclosure of the personal data is in the legitimate interests of TWPC-EC or another organisation; or

(g)       where required for any purpose reasonably related to, and/or necessary in order for us to fulfil, the purposes for collection, use and/or disclosure of personal data in accordance with the PDPA and this Policy.

2.2      In general, we may collect, use and disclose personal data where necessary, and to the extent reasonably required, for one or more of the following purposes:

(a)       To minister to members and worshippers of the TWPC-EC;

(b)       To provide pastoral care and other services;

(c)       To organise and conduct events, activities and programmes that are part and parcel of church life;

(d)       To establish, maintain and strengthen relationships between TWPC-EC and its members and worshippers and generally among its members and worshippers;

(e)       To provide social services and support;

(f)        To provide information relating to the Church and/or the Presbyterian Church in Singapore to members, worshippers, visitors and others, including (but not limited to) information about church ministries, services, news, events and programmes (via newsletters, email, SMS, social media and other means);

(g)       To process tithes, donations and payments related to any services, events and programmes administered by TWPC-EC;

(h)       To process a member’s proxy voting form and generally anything related to your queries, requests, rights and obligations as a member of TWPC-EC;

(i)        (For prospective employees) To assess employment applications and the suitability of applicants for available positions;

(j)        For management and administration of the Church and TWPC-EC including (but not limited to) security, audit, accounting and tax purposes;

(k)       For any purpose as required by law;

(l)        For any other purpose which we may notify you from time to time; 

(m)      For personal data collected before 2 July 2014, for any purpose for which the personal data was collected; and

(n)       For any purpose reasonably related to and/or required for any of the foregoing purposes.

2.3      We may disclose personal data as reasonably required under paragraphs 2.1 and  2.2 to:

(a)       Our employees, pastors, elders, deacons, volunteers and members of TWPC-EC;

(b)       The Chinese Congregation of the Church;

(c)       The English Presbytery and the Synod of the Presbyterian Church in Singapore;

(d)       Our agents, contractors and/or third party service providers (including providers of professional services such as audit and legal services);

(e)       Any other person or organisation where you have consented to such disclosure; and

(f)        Any other person or organisation where permitted or required by law or an order of court.

2.4      We may produce data in aggregated and/or de-identified form from the personal data we hold such that it no longer linked to a particular individual (“anonymised data”). We may use anonymised data for statistical, analytical or other purposes and disclose anonymised data to other organisations for such purposes.

 

3. CONSENT AND WITHDRAWAL OF CONSENT

3.1      Subject to any other data protection notice and/or terms and conditions which you may agree to, if you provide any personal data to TWPC-EC, whether directly or through a third party, you agree and consent to its collection, use and/or disclosure by TWPC-EC in accordance with this Policy.

3.2      You may withdraw any consent given or deemed to have been given by you in relation to the collection, use and/or disclosure of your personal data by giving us not less than fourteen (14) days prior notice in writing, via post or via email to our  address as stated above.

3.3      In the event you withdraw consent for the collection, use and/or disclosure of personal data in accordance with paragraph 3.2, we shall, subject to paragraph 3.4, cease to collect, use, and/or disclose your personal data within the scope of your withdrawal of consent, in which case we may be unable to provide specific services or address your specific pastoral needs.

3.4      Withdrawal of consent does not affect our collection, use and/or disclosure of personal data without consent in accordance with the PDPA or other written laws.

 

4. ACCESS TO, AND CORRECTION OF, PERSONAL DATA

4.1      You may make a request for access to, or correction of, your personal data which is in our possession or under our control in accordance with (and subject to) the PDPA.

4.2      Please submit your requests in writing, via post or email to our address as stated above. Your request must state your name and the nature and scope of your request, including the personal data you are seeking access to or correction of. We shall inform you if we require additional information or documents to verify your identity and process your request.

4.3      Depending on the nature and extent of your request, we may impose a reasonable fee in accordance with the PDPA to provide access to the requested personal data (for example, if there are costs incurred in providing copies of the requested personal data).

 

5. CARE OF PERSONAL DATA

5.1      Accuracy of Personal Data

5.1.1   We shall take reasonable steps to ensure that personal data collected by us is accurate and complete if the data is likely to be –

            (a)       used by us to make a decision that affects you; or

            (b)       disclosed by us to another organisation (in accordance with the law).

5.1.2   We are entitled to assume that personal data submitted directly to you by you is accurate and complete. Please update us through the Church office if there is any change if the data you provided (for example, change of contact information).

5.2      Protection of Personal Data and Notification of Data Breaches

5.2.1   We shall protect personal data in our possession or under our control by making reasonable security arrangements to prevent loss or unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

5.2.2   In the event of a data breach affecting your personal which may cause significant harm (as determined under the PDPA), we shall notify you in accordance with (and subject to) the PDPA.

5.3      Retention of Personal Data

5.3.1   We retain personal data as long as required for the purposes stated above (including any other purpose we may notify you from time to time) or any other purpose permitted by law.

5.3.2   We shall cease to retain documents containing your personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for any other purpose permitted by law.

5.4      Transfer of Personal Data Outside Singapore

5.4.1   If we transfer your personal data to a country or territory outside Singapore (for example, where we use cloud services for the storage and processing of personal data or where specifically required for a purpose), we shall take the relevant action, in accordance with the PDPA, to provide a standard of protection to the transferred personal data that is comparable to the protection under the PDPA.

 

6. EXERCISE OF RIGHTS BY, OR ON BEHALF OF, INDIVIDUALS

6.1      General

6.1.1   In general, individuals must exercise their rights under the PDPA in person. In certain circumstances, for example, where an individual’s consent is required under the PDPA, the individual may authorise another person to exercise such rights (e.g. give consent) on his or her behalf.

6.1.2   Where an individual is legally incapable of exercising his or her rights under the PDPA, such rights may be exercised by a person who is legally authorised to do so on his or her behalf.

6.2      Minors (Children)

6.2.1   Without limiting the foregoing, where consent is required for the collection, use, and/or disclosure of personal data of a minor (child) below 18 years of age, we shall obtain such consent from a parent or legal guardian of the minor.

6.3      Deceased Individuals

6.3.1   The PDPA applies to a limited extent in relation to the personal data of deceased individuals. Rights under the PDPA relating to the personal data of a deceased individual may be exercised by a person who is authorised by law to make such a request, such as the executor of the deceased individual’s will, administrator of the deceased individual’s estate or the nearest relative of the deceased individual as determined under the PDPA.

 

7. TWPC-EC WEBSITE AND INFORMATION SENT THROUGH THE INTERNET

7.1      The website of TWPC-EC, located at https://truewaypc.com (and including all its sub-pages) (“Website”), mainly provides information relating to our ministries, services, events and programmes in Singapore.

7.2      The Website may use cookies. A cookie is a small piece of information that is sent to your browser and stored on your computer’s hard drive. Cookies are widely used to aid in the operation of websites, for example, by storing your preferences or enabling users to remain logged in to a website. Cookies may also be used track information such as frequency, date, time and duration of use of a website, the specific web pages visited within a website, the address of any referring website, the user’s device operating system and web browser type, and the user’s IP address. Cookies do not identify you personally and cannot read data off your hard disk. You can set your browser to accept or decline cookies or to notify you when you receive a cookie. If you decline to accept cookies on the Website, this may prevent you from taking full advantage of its features.

7.3      The Website may contain hyperlinks to other websites that are not operated by TWPC-EC whose data protection and privacy policies and practices may differ from ours. The provision of such hyperlinks is for convenience only and does not imply that we endorse the contents, policies and practice of those other websites. In particular, we are not responsible for the contents and the data protection and privacy policies and practices of those other websites.

7.4      In general, personal data collected through the Website or sent to us via email is subject to this Policy and any data protection notice on the relevant page or form on this Website through which personal data was collected.

7.5      Although we have, as stated above, put in place reasonable security measures to protect personal data, nevertheless, you should not use the Website to send us confidential or sensitive personal data as there may be circumstances beyond our control which may affect the security of such transmissions (for example, if you are accessing the Internet via a public WiFi point or on a shared device).

7.6      We reserve the right to respond to messages posted online which relate to, or have a bearing on, TWPC-EC or its activities.

 

8. ENFORCEABILITY

8.1      Without prejudice to an individual’s right of private action under the PDPA, nothing in this Policy shall create or confer on any individual any legally enforceable rights whether by way of contract, tort, equity or otherwise under the law.