Tripartite Alliance Limited
Personal Data Policy
Updated as at 25 April 2018
1. The Tripartite Alliance Limited (“TAL”) is jointly set up and owned by the Ministry of Manpower (“MOM”), the National Trades Union Congress (“NTUC”) and the Singapore National Employers Federation (“SNEF”). It comprises TAL Management and Corporate and the following agencies:
- Tripartite Alliance for Fair and Progressive Employment Practices (“TAFEP”)
- Tripartite Alliance for Dispute Management (“TADM”)
- Workplace Safety and Health Council (“WSHC”)
2. This policy informs you how TAL handles your Personal Data under the Personal Data Protection Act 2012 (Cap. 26) (“PDPA”). Under PDPA, Personal Data is defined as information about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.
3. TAL collects, uses or discloses Personal Data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified, or is required or allowed under applicable laws.
Specifically, if you choose to submit any information, report, dispute or claims or send us any email, you will be deemed to have provided explicit personal consent or, where applicable, obtained third party consent, to provide information, including Personal Data to TAL. You also provide personal or representative consent to this information disclosure by any or both of us to the following parties and to subsequent disclosure among same parties of any and all information including, without limitation, Personal Data that may have been possessed or collected in connection with your information, report, dispute or claims:
- Tripartite Alliance Limited;
- Appropriate government regulatory bodies or public agencies (including inter alia, the MOM and the State Courts);
- Authorised parties (including inter alia, employers, SNEF, NTUC or any other union, NTUC U Care Centre and Migrant Workers’ Centre);
- Any third party engaged to maintain, repair or enhance this website or otherwise perform services for us for any purpose deemed appropriate by any or both of us.
4. TAL collects, uses and discloses your Personal Data to:
- Promote, implement, recognise and raise fair and progressive employment practices which further our vision of progressive workplaces and harmonious work relations;
- Help employees and employers manage employment disputes amicably through advisory and mediation services;
- Promote, implement, recognise and raise workplace safety and health standards which realises the national vision for Singapore.
Collection of your Personal Data
5. TAL collects your Personal Data through the following means:
- when you communicate and interact with us via telephone, website, e-mail, letters, face-to-face meetings, social media, mobile applications and others. Telephone calls to our hotlines may be recorded;
- when you provide your organisation’s information to adopt or apply for our workplace programmes and grant funding;
- when you enquire or feedback about cases related to job advertisement, workplace practice or others;
- when you respond with or submit Personal Data on cases, disputes or joint TAL-MOM employer assessments;
- when you respond to events, surveys, awards, promotions, competitions, contests, lucky draws or other activities conducted or organised by us;
- when you have CCTV recordings, photographs or videos (taken by us or our representatives) during your interviews or visits at our premises or events hosted by us;
- when you request for mailing list inclusion with us;
- when you serve or apply to serve as an industry or functional committee or management board member;
- when you apply to join as an intern or employee;
- when you submit financial information such as bank account numbers or others;
- when you submit your Personal Data for any other reason.
6. We only collect, process, use or disclose such Personal Data, in accordance with this policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy by referring them to our agencies’ website. Where applicable, for any third parties’ prior disclosure of your personal data, you shall also undertake that they were done so with your consent and authorisation.
7. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).
How we use your Personal Data
8. TAL collects and uses your Personal Data for the following purposes:
- respond to requests or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);
- register representatives, organisationally or individually, for TAL’s programmes;
- management of programmes and grant funding administration;
- provide employer training and education, including events and seminars;
- provide workplace practice engagement reviews for enhancement purposes;
- process, advise, mediate and manage cases, disputes or joint TAL-MOM employer assessments;
- provide assistance with the enforcement of court orders;
- facilitate access to financial/social assistance;
- provide you updates through our mailing broadcast and/or social media platforms on our news, research, laws, regulations, progressive practices, case studies, programmes, events, awards, initiatives, competitions, contests, lucky draws or other activities;
- for case studies in our publications and media profiling;
- compile statistics and findings including aggregated findings for submission to government authorities (including MOM), agencies or to respond to media queries;
- conduct market research and analysis including customer satisfaction or other surveys and polls to develop or enhance our programmes and services;
- monitor or record phone calls for service quality assurance and employee training;
- manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances when required);
- obtain approval to serve in WSHC Industry or functional committees;
- for recruitment and employment;
- for general management and internal reporting, invoicing and account management;
- for compliance with laws, regulations, guidelines, directions and other similar requirements;
- for purposes incidental to each or all of the above.
Disclosure of your Personal Data
9. TAL may disclose Personal Data for the following reasons:
- to an organisation and where applicable, the MOM, the State Courts and authorised parties (including inter alia, employers, SNEF, NTUC or any other union, NTUC U Care Centre and Migrant Workers’ Centre) to follow up on your case unless you expressly inform us otherwise;
- to relevant authorities (including MOM) and other government regulatory bodies (including the State Courts) upon their official requests;
- to any other party to whom you authorise us to disclose your Personal Data;
- to an intern, employee, independent contractor or data intermediary providing services to support TAL, whom are under a duty of confidentiality to TAL;
- to the extent necessary to comply with laws, guidelines, directions and other similar requirements.
10. TAL does not disclose Personal Data to third parties except when we have your consent or deemed consent, is required by law or where we have engaged third party contractors or data intermediaries and/or sub-contractors (“TAL connected entities”) to process Personal Data on behalf of TAL. Any such third parties whom we engage may have servers located outside of Singapore while parties are required to comply with the PDPA obligations including protection for data transferred overseas.
Third Parties’ Links and Transfer of Personal Data to Countries (Outside Singapore)
11. This site may contain links to other sites whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult the privacy notices of those sites.
12. 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.
Accuracy, Retention and Protection
13. If you are only browsing this website, we do not capture data that allows us to identify you individually.
14. TAL relies on you to ensure that your Personal Data provided is current, complete and accurate. For your convenience, we may display to you data you had previously supplied us. This will speed up the transaction and save you the trouble of repeating previous submissions. Should the data be out-of-date, please supply us with the latest data.
15. TAL will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such Personal Data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
16. To protect your Personal Data, all electronic storage and transmission of Personal Data is access controlled and secured with appropriate security technologies such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third-party service agents only on a need-to-know basis.
17. Although every reasonable effort has been made to ensure that all Personal Data will be so protected, you should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Withdrawal, Enquiry and Contact
18. You may refuse or withdraw your consent given, or deemed to have been given, for us to collect, use or disclose your Personal Data by giving us reasonable notice, in writing. Where you do so, this may affect our ability to provide our product or service to you. We will stop (and cause any of our TAL connected entities to stop) collecting, using or disclosing the Personal Data unless it is required or allowed under applicable laws.
19. TAL may update this Policy from time to time to reflect changes in law or business. TAL will keep 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.
20. Please contact our Data Protection Officer at DPO@tal.sg if you:
- have any enquiries on TAL’s Personal Data Policy;
- need more information on or access to the data which you have provided to us in the past.
Effect of Notice and Changes to Policy
21. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
22. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.