Privacy Policy

BSL GROUP (“BSL”)

This Policy sets out the manner in which BSL collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 (“PDPA“).

This Policy applies to all Individuals (as defined below) who provide BSL with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by BSL in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to BSL, nor does it affect any rights that BSL may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, BSL will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with the Personal Data or as required for the purposes of providing services to the Individual or by law.

BSL may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at www.bsl.sg (“BSL Website”) and appropriate notifications of any material revisions will be published on the BSL Website and may be issued separately to relevant persons such as may be determined by BSL. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with BSL after any amendments have been introduced and published on the BSL Website, Individuals shall be deemed to have accepted the Policy as amended.

For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with BSL (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

1. Definitions: For purposes of this Policy:
2. “Individual” means a natural person, whether living or deceased and “Individuals” shall be construed accordingly;
3. “CCTV” means Closed-circuit Television;
4. Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to BSL;
5. “Personnel” means any Individual engaged under a contract of service with BSL, a contract for service with BSL, permanent or temporary employees as well as trainees and interns engaged by BSL from time to time; and “Potential Personnel” means any Individual who has submitted an application to be engaged by BSL as Personnel.
6. Personal Data collected by BSL
7. the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
8. details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
9. details of the Individual’s employment history and academic qualifications;
10. the name and contact particulars of the Individual’s next-of-kin;
11. the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
12. photographs and video or CCTV recordings of the Individual; and
13. other information which the Individual may provide to BSL, from time to time, in the course of such Individual’s interaction with BSL.
14. How BSL collects Personal Data
15. when the Individual interacts with BSL’s staff via telephone calls, emails, other correspondence and/or face-to-face meetings;
16. when the Individual visits BSL’s premises;
17. when the Individual specifically requests that BSL contact him or her or requests to be included in an email or any mailing list maintained by BSL;
18. when the Individual responds to any request by BSL for the provision of Personal Data;
19. when BSL receives references or referrals from its business partners or other third parties;
20. when the Individual attends or participates in any event organised by BSL;
21. when the Individual submits his or her Personal Data to BSL pursuant to a job application;
22. when the Individual subscribes to BSL’s publication(s); and/or
23. when the Individual submits his or her Personal Data to BSL for any other reason related to BSL’s ordinary course of business operations.
24. Purposes of collection, use and disclosure of Personal Data
25. Provision of services
    1. administering and managing the Individual’s relationship with BSL;
    2. providing the Individual with information about BSL’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with BSL;
    3. responding to the Individual’s complaints, queries and/or requests;
    4. facilitating and/or organising events;
    5. informing the Individual of changes and/or updates to BSL’s policies, terms and conditions and/or other administrative information;
26. Security measures
    1. verifying the Individual’s identity or monitoring the Individual’s activities, including without limitation via CCTV observation and/or recording;
    2. preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned; and
    3. accessing to individual’s personal data is only available to the staff who require it to perform their duties. All such staff have entered into non-disclosure agreements with BSL to treat the personal data as confidential information.
27. General business operations of BSL
    1. Provision of audit, accounting, administrative, payroll, taxation and consulting services;
    2. record-keeping and meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on BSL (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting audit checks, due diligence and investigations);
28. Managing Personnel
    1. administering, managing and/or terminating BSL’s relationship with Personnel;
    2. evaluating the performance of Personnel;
    3. undertaking staff training and quality assurance activities;
    4. providing Personnel with services, facilities and/or other benefits being offered or made available by BSL to such Personnel as well as information about such services, facilities and benefits;
29. Managing Potential Personnel
    1. administering and managing BSL’s relationship with Potential Personnel;
    2. evaluating the suitability and eligibility of Potential Personnel to be engaged by BSL;
30. Marketing
    1. where BSL circulates BSL’s publications or marketing information to an Individual or to any person which may be disseminated to and individual relating to services offered by BSL (whether by BSL or BSL’s business partners) which BSL thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);
    2. for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by BSL;
31. Others
    1. for transfer to third party data intermediaries such as third party service providers and agents to facilitate any of the aforesaid purposes;
    2. for any purposes reasonably related to any of the above purposes; and
    3. for any other purposes in relation to which BSL has specifically obtained the Individual’s consent.
32. Retention of Personal Data
33. Consent
34. via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to BSL;
35. via notifications on BSL’s websites;
36. in the course of verbal communications;
37. voluntarily provide their Personal Data to BSL for the specified purposes;
38. use or access BSL’s website(s) or computer network;
39. enter BSL’s premises or using any of the facilities thereon; and/or
40. attend or participate in events or programmes organised by BSL.
41. Disclosure of Personal Data
42. to BSL’s third party service providers or agents;
43. any external vendor that is providing services or products in partnership or collaboration with BSL;
44. to BSL’s professional advisors;
45. any person to whom disclosure is permitted or required by any statutory provision or law;
46. any permitted assigns; and/or
47. to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.
48. Withdrawal of Consent
49. Verification of Personal Data & Notification of Changes
50. Activities undertaken prior to 2 July 2014
51. Protection of Personal Data
52. Contacting BSL-Access and Correction of Personal Data
53. has questions or feedback relating to this Policy;
54. would like to obtain access to his or her Personal Data held by BSL;
55. would like to obtain information about the ways in which his or her Personal Data held by BSL has been or may have been used or disclosed by BSL in the year preceding the request; and/or
56. would like to update or make corrections to his or her Personal Data held by BSL,
57. Governing