SMU Personal Data Protection Statement
Applicable to non-EU Data Subjects only. Learn more about GDPR Privacy Statement applicable to EU Data Subjects.
SMU 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.
“Personal data” is defined in the Act as “data, whether true or not, about an individual who can be identified – a) from that data; or b) from that data and other information to which the organisation has or is likely to have access.”
The Act takes into account the following concepts:
Consent – Organisations may collect, use or disclose personal data only with the individual's knowledge and consent (with some exceptions);
Purpose – Organisations may collect, use or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use or disclosure; and
Reasonableness – Organisations may collect, use or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances.
In projecting the three main concepts above, the Act contains nine main obligations which organisations are expected to comply with if they undertake activities related to the collection, use and/or disclosure of personal data:-
- The Consent Obligation
- The Purpose Limiting Obligation
- The Notification Obligation
- The Access and Correction Obligation
- The Accuracy Obligation
- The Protection Obligation
- The Retention Limitation Obligation
- The Transfer Limitation Obligation
- The Accountability Obligation
- The Data Breach Notification Obligation
- The Data Portability Obligation
While we will not be going into the details of these Obligations in this Personal Data Protection Statement, you can be rest assured that we are constantly mindful of them in our collection, use and disclosure of personal data. Should you wish to know more about these obligations, an excellent summary can be found in the Advisory Guidelines of the Personal Data Protection Commission at:
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 purposes.
Depending on your relationship with us, the personal data which we collect from you may be used and/or disclosed for the following purposes:
For Students Generally
Most of you will have consented to SMU using your personal data in the manner set out in the online matriculation form used when you first matriculated into SMU; or when you use specific services and facilities offered by the University; or when students are notified by the University administration of new rules and policies applicable to the student body and are deemed to have consented to the same. The information below serves only to supplement and clarify this matter, without limiting the scope of your earlier consent:
- Evaluating suitability for admission or employment, enrolling or employing, providing educational courses and training, including sending materials on course / study / assignment / lecture materials, information on time tables and examination details via various means, including postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
- Administering and/or managing relationships with SMU (including responding to enquiries, the mailing of correspondence, statements or notices which could involve the disclosure of certain personal data to bring about delivery of the same);
- Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by SMU, including the obtaining of references and/or other information from prior educational institutions and employers;
- Processing application(s) for scholarships and/or financial aid, and research support, and administering and managing scholarship/financial aid/grant and other support programmes, which may include use of personal data for development and fund raising activities and disclosure of personal data to donors, grantors, external evaluators and/or external organisations for purposes of assessment, periodic reports, event invitations, surveys and/or publicity of SMU related programmes;
- Investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities;
- Responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorised to carry out specific Government services or duties;
- Carrying out market-related, evaluative or similar research and analysis for SMU’s operational strategy and policy planning purposes, including providing data to external parties for university programme evaluation and to students’ former academic institutions and to partner institutions for jointly-administered programmes;
- Outreach and engagement to garner support and resources for SMU, its community and affiliated institutions;
- Supporting SMU functions including, but not restricted to, the teaching and personal and professional development of students, research and administration of SMU;
- Processing and administering applications for overseas exchange programmes, summer school, overseas internships and other overseas activities and administering such programmes including disclosure of information to overseas universities / institutions, employment and training organisations;
- Processing, administering and conferring awards of prizes, medals, scholarships, classes of honours and other marks of distinction, and student or graduation status, and publication or releasing of information on the same;
- Engaging alumni including but not limited to notification on SMU and alumni-related initiatives and activities, invitation to SMU and alumni-related events, updating of alumni information, invitation to participate in alumni surveys and sending of communication collaterals;
- Processing applications and enrolment activities related to health, life and travel insurance and service provision as well as university-related concession cards, and campus accommodation and administering matters related to use of these services;
- Processing applications for and administering local and overseas career related activities, events, programmes, internships, employment opportunities, and career coaching, and sharing information with companies (whether local or overseas) for purposes of recruitment, internships, industrial attachment, job placement and research support;
- Facilitating participation in student life and alumni development opportunities which may include social, cultural, athletic, and educational activities, events, volunteering and training programmes, student membership and leadership positions in clubs, societies, halls and residences, and orientation/reception activities;
- Taking of photographs and/or videos (whether by SMU staff or third party photographers and/or videographers) during events or seminars organised by SMU or its affiliates for publicity purposes;
- If consented to in the registration form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
- Any other purpose arising in respect of the environment within which an institution of higher learning such as SMU operates which is reasonable given your relationship with SMU;
- Any other purposes not related to those listed above or in the online matriculation form to which you consented, which SMU may inform you from time to time, but for which SMU will seek your separate consent.
For Employees/Staff Generally
In order to comply with its contractual, statutory, and management obligations and responsibilities, the University is required to process personal data relating to its employees. All such data will be processed in accordance with the provisions of the Act and the relevant University’s rules and policies, including those on data protection, as may be amended from time to time. Your relationship with SMU will, in almost all cases, be governed primarily by an employment Contract, and your agreement to be bound by the Employee Handbook and/or Governance and Academic Policies Handbook (which may be revised from time to time), any of which will very often inform you expressly or impliedly the purposes for, and the manner in, which your personal data will be used. The purposes listed below serve only to supplement and clarify the matter, without limiting, superseding or supplanting any express or implied terms in the abovementioned documents:
- for managing your employment relationship with SMU;
- for using your bank account details to deposit salaries and other payments;
- for monitoring the use of SMU’s computer network resources;
- for posting your photographs on SMU’s intranet and website, staff pass, newsletters and the like;
- for managing staff benefit schemes;
- for disclosing your personal data where necessary to external parties for purposes of University administration, and 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;
- for investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities;
- any other purpose arising in respect of the environment within which an institution of higher learning such as SMU operates which is reasonable given your relationship with SMU; and
- any other purposes not related to those listed above or in your employment contract, which SMU may inform you of in writing from time to time, but for which SMU will seek your separate consent.
For The Public and Other Third Parties Generally
SMU is committed to engaging and embracing its surrounding community, ecosystem as well as society at large. As a result, we often organise a lot of activities in which external stakeholders or the general public are invited to participate. While it is impossible to list all the events in which we hope the public will participate, some events that you as a member of the public can look forward to include community outreach programmes, talks, exhibitions, movie screenings, concerts and many others ("Events"). Naturally, in encouraging a vibrant interaction with the public, there will be opportunity, and often a need, to collect, use and/or disclose personal data from members of the public. Some of the reasons/ purposes are as follows:
- Investigative, security and verification purposes, including, without limitation, possible fraud, misconduct, harassment, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities
- For logistical/ administrative purposes for certain Events (eg. Food catering)
- To keep you updated of future SMU Events/ products which we feel may interest you
- For marketing/ publicity purposes (eg. Photographs)
- For any other purpose arising in respect of the environment within which an institution of higher learning such as SMU operates which is reasonable given your relationship with SMU.
In almost all of the above situations, it will be totally up to you as to whether, and to what extent, you wish to provide us with your personal data. For Events where such provision of personal data is a pre-requisite to attendance, you shall be informed in advance so that you may make an informed decision as to whether to attend. SMU will also endeavour at all times to inform you of the purposes for which personal data collected from you will be used. Should you at any time feel that the manner in which SMU has acted, or seeks to act, in respect of the collection, use or disclosure of personal data for an Event is inappropriate, please feel free to make your concerns known to the Data Protection Officer, whose contact details can be found at http://www.smu.edu.sg/form/contact-dpo
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 contacting the Data Protection Officer.
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 SMU within a year before the date 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.
For Students: If, for any reason whatsoever and at any time during your period of study with SMU, you are uncomfortable with the manner or extent of collection, use and/or disclosure of your personal data, you are advised to inform your Dean or the Dean of Students so that a reasonable and mutually acceptable solution to your concerns can be found.
For Employees/Staff: If, for any reason whatsoever and at any time during your period of employment at SMU, you are uncomfortable with the manner or extent of collection, use and/or disclosure of your personal data, you are advised to inform your immediate supervisor, Head of Department or Dean so that a reasonable and mutually acceptable solution to your concerns can be found.
For the public and other third parties: In some cases, requests for withdrawal may adversely impact your relationship with SMU as it may hinder SMU's ability to continue to interact with you. We will notify you in advance of such impact, if any.
4. Administration and Management of Personal Data
We will take appropriate measures to keep your personal data accurate, complete and updated.
We will also take reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.
We will also take reasonable efforts to ensure that the personal data in our possession or under our control is destroyed 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.
Our websites may contain links to other websites not maintained by SMU. 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. Responsibility of EMPLOYEES (Staff, Faculty), STUDENTS AND OTHER STAKEHOLDERS
The Act also imposes certain responsibilities on all those who process personal data at the University, whether you are a member of staff holding, using and sharing personal data in your teaching, research or administration, or a student accessing and recording personal data in your studies or other activities. These obligations include holding and using data in a secure manner, making sure that data is handled in line with what individuals have been told, having appropriate arrangements in place for the access to (and sharing of) data, and making sure that individuals' data is accurate and retained for a suitable period. If a data breach occurs (e.g. personal data held by the University is lost, stolen, inadvertently disclosed to an external party, or accidentally published), this should be reported immediately to your seniors and the Data Protection Officer so that we may review the circumstances and liaise as necessary with colleagues internally and the relevant external authorities.
6. CONTACT US
If you have any questions about the Privacy Statement, please contact Data Protection Officer at:-
dpo@smu.edu.sg
GDPR Privacy Statement
Applicable to EU Data Subjects only
The General Data Protection Regulation (GDPR) is a new EU framework for data protection that will apply from 25 May 2018.
The framework applies to all businesses processing and holding the personal information of data subjects residing in the European Union, regardless of where the business is located.
SMU is working to align our privacy framework and business practices with the GDPR, which offers a range of new and enhanced rights for individuals. A University-wide improvement programme is currently underway to further strengthen the way in which we protect personal information.
More information on the GDPR is available on https://www.pdpc.gov.sg/-/media/files/pdpc/pdf-files/eu-gdpr/eu-gdpr-factsheet--041017.pdf and https://www.pdpc.gov.sg/Help-and-Resources/2017/10/EU-GDPR
1. Introduction
1.1 Singapore Management University (“SMU”) would need to collect, store and process your personal data for legitimate purposes in order to carry out its functions and activities to serve you. SMU may either be a Controller or a Processor of your personal data. Either way, SMU is committed to full compliance with the General Data Protection Regulation (“GDPR”) with respect to your personal data.
1.2 SMU’s Data Protection Officer is responsible for informing and advising SMU and its staff on its data protection obligations, and for monitoring compliance with those obligations. If you have any questions or comments about the content of this Privacy Statement or if you need further information, you should contact the Data Protection Officer via email at dpo@smu.edu.sg.
1.3 “Personal data” means any information relating to an identified or identifiable natural person (referred to as a ‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
1.4 “EU Data Subject” in this Privacy Statement means any person located in the European Union (EU).
2. Protection principles
2.1 SMU will comply with the following data protection principles when processing personal data:
2.1.1 we will process personal data lawfully, fairly and in a transparent manner;
2.1.2 we will collect personal data for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
2.1.3 we will only process the personal data that is adequate, relevant and necessary for the relevant purposes;
2.1.4 we will keep accurate and up to date personal data, and take reasonable steps to ensure that inaccurate personal data are deleted or corrected without delay;
2.1.5 we will keep personal data in a form which permits identification of EU Data Subjects for no longer than is necessary for the purposes for which the personal data are processed; and
2.1.6 we will take appropriate technical and organisational measures to ensure that personal data are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
2.2 SMU is also responsible to demonstrate compliance with the above data protection principles.
3. Basis for processing personal data
3.1 In relation to any processing activity that involves personal data, we will before the processing starts for the first time:
3.1.1 review the purposes of the particular processing activity, and select the most appropriate lawful basis for that processing, that is:
- that the EU Data Subject has consented to the processing;
- that the processing is necessary for the performance of a contract to which the EU Data Subject is party or in order to take steps at the request of the EU Data Subject prior to entering into a contract;
- that the processing is necessary for compliance with a legal obligation to which SMU is subject;
- that the processing is necessary for the protection of the vital interests of the EU Data Subject or of another natural person;
- that the processing is necessary for the performance of a task carried out in the public interest or exercise of official authority by SMU; or
- where SMU is not carrying out tasks as a public authority, that the processing is necessary for the purposes of the legitimate interests SMU or a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the EU Data Subject.
3.1.2 except where the processing is based on consent, satisfy ourselves that the processing is necessary for the purpose of the relevant lawful basis;
3.1.3 document our decision as to which lawful basis applies, to help demonstrate our compliance with the data protection principles;
3.1.4 include information about both the purposes of the processing and the lawful basis for it in our privacy notices to you; and
3.1.5 in the event that SMU processes sensitive personal data, SMU will identify a lawful special condition for processing that information (see paragraph 4 below), and document it.
4. Sensitive personal data
4.1 Sensitive personal data (sometimes referred to as ‘special categories of personal data’) are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.
4.2 In SMU, at the present moment the processing of sensitive personal data is prohibited regardless of the legal basis set out in paragraph 3.1.1 (a) to (f), above.
5. Data privacy impact assessment (“DPIA”)
Where processing is likely to result in a high risk to an individual’s data protection rights (e.g. where SMU is planning to use a new form of technology), we will, before commencing the processing, carry out a DPIA to assess:
5.1 whether the processing is necessary and proportionate in relation to its purpose;
5.2 the risks to individuals; and
5.3 what measures can be put in place to address those risks and protect personal data.
6. Documentation and records
6.1 We will keep records of processing activities in accordance with the requirements of the GDPR.
6.2 We will conduct regular reviews of the personal data we process and update our documentation accordingly. This may include:
6.2.1 carrying out information audits to find out what personal data SMU holds;
6.2.2 distributing questionnaires and talking to staff across SMU to get a more complete picture of our processing activities; and
6.2.3 reviewing our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
7. Privacy notices
7.1 SMU will issue privacy notices from time to time, informing the people from whom we collect information about the personal data that we collect and hold relating to them, how they can expect their personal data to be used and for what purposes.
7.2 We will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
8. Individual rights
8.1 EU Data Subjects have the following rights in relation to their personal data:
8.1.1 to be informed about how, why and on what basis that data is processed;
8.1.2 to obtain confirmation that their data is being processed and to obtain access to it and certain other information, by making a subject access request;
8.1.3 to have data corrected if it is inaccurate or incomplete;
8.1.4 to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
8.1.5 to restrict the processing of personal data where the accuracy of the information is contested, or the processing is unlawful (but the EU Data Subject does not want the data to be erased), or where SMU no longer needs the personal data but the EU Data Subject requires the data to establish, exercise or defend a legal claim; and
8.1.6 to object to the processing of personal data based on the legal basis stated in paragraph 3.1.1 (e) or (f) unless SMU demonstrates compelling legitimate grounds for the processing which override the EU Data Subject’s interests or for the establishment, exercise or defence of legal claims.
9. Information security
9.1 SMU will use appropriate technical and organisational measures in accordance with the SMU’s IT Security Policy and related policies to keep personal data secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. These may include:
9.1.1 making sure that, where possible, personal data is password-protected or pseudonymised or encrypted;
9.1.2 ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
9.1.3 ensuring that, in the event of a physical or technical incident, availability and access to personal data can be restored in a timely manner; and
9.1.4 a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
9.2 Where SMU uses external organisations to process personal data on its behalf, if necessary and where appropriate, additional security arrangements shall be implemented in contracts with those organisations to safeguard the security of personal data. In particular, contracts with external organisations shall provide that:
9.2.1 the organisation may act only on the written instructions of SMU;
9.2.2 those processing the data are subject to a duty of confidence;
9.2.3 appropriate measures are taken to ensure the security of processing;
9.2.4 sub-contractors are only engaged with the prior consent of SMU and under a written contract;
9.2.5 the organisation will assist SMU in providing subject access and allowing individuals to exercise their rights in relation to data protection;
9.2.6 the organisation will assist SMU in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments;
9.2.7 the organisation will delete or return all personal data to SMU as requested at the end of the contract; and
9.2.8 the organisation will provide SMU with whatever information it reasonably needs to ensure that they are both meeting their data protection obligations.
10. Retention of Personal Data
10.1 Personal data will be kept securely for no longer than is necessary for the purposes for which the data are processed.
10.2 Personal data would not be retained for any longer than necessary. The length of time over which data would be retained will depend upon the circumstances, including the reasons why the personal data was obtained.
10.3 Personal data that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.
11. Data breaches
11.1 A data breach may take many different forms, for example:
11.1.1 loss or theft of data or equipment on which personal data is stored;
11.1.2 unauthorised access to or use of personal data either by a member of staff or third party;
11.1.3 loss of data resulting from an equipment or systems (including hardware and software) failure;
11.1.4 human error, such as accidental deletion or alteration of data;
11.1.5 unforeseen circumstances, such as a fire or flood;
11.1.6 deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and/or
11.1.7 where information is obtained by deception.
11.2 SMU will:
11.2.1 investigate any reported actual or suspected data security breach;
11.2.2 where applicable, make the required report of a data breach to the relevant supervisory authority without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
11.2.3 notify the affected individuals if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
12. International transfers
12.1 SMU may transfer personal data to a third country or an international organisation only if the recipient has provided appropriate safeguards (for example, by way of standard data protection clauses) or where we obtain the EU Data Subjects’ explicit consent to such transfers after they have been informed of the possible risks of such transfers.
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