Singapore PDPA compliant school management software

Personal Data Protection Act 2012 (PDPA) - Singapore



Eduwonka is committed to comply with PDPA i.e. Personal Data Protection Act 2012. Eduwonka maintains high transparency, values customer’s data and therefore complies with PDPA which governs the collection, use and disclosure of personal data by organizations.

PDPA came into existence from November 2012 while the Info‑communications Media Development Authority Act commenced from October 2016. Notably, the Info-Communications Media Authority is designated as the Personal Data Protection Commission.

1.General rules
Adhering to PDPA we declare that, Eduwonka —
(1) Is responsible for personal data in its possession or under its control.
(2) Shall designate one or more individuals responsible for ensuring that Eduwonka complies with PDPA.
Eduwonka will make the business contact information of at least one of the designate individuals public.

Further, Eduwonka shall — (3) develop and implement policies and practices that are necessary to meet the obligations under PDPA and will communicate the same to its staff;
(4) develop a process to receive and respond to complaints that may arise with respect to the application of PDPA.

2. Consent Required
Eduwonka shall not, collect, use or disclose personal data about an individual unless—
(1) the individual gives, or is deemed to have given, his consent under PDPA to the collection of Eduwonka, use or disclosure, as the case may be;
(2) the collection, use or disclosure, as the case may be, without the consent of the individual is required or authorized under PDPA or any other written law.

3. Provision of Consent
(1) An individual has not given consent under PDPA for the collection, use or disclosure of personal data about the individual by Eduwonka for a purpose unless —
(a) the individual has been provided with the information required (under section 20) i.e. Notification of purpose. Under this, Eduwonka shall inform the individual of —
ⅰ. the purpose for the collection, use or disclosure of the personal data, as the case may be, on or before collecting the personal data;
ⅱ. any other purpose of the use or disclosure of the personal data of which the individual has not been informed under paragraph (i), before the use or disclosure of the personal data for that purpose;
ⅲ. on request by the individual, the business contact information of a person who is able to answer on behalf of Eduwonka the individual’s questions about the collection, use or disclosure of the personal data.

Here (1) shall not apply if —
(a) the individual is deemed to have consented to the collection. use or disclosure, as the case may be, under Section 15.
(b) Eduwonka collects, uses or discloses the personal data without the consent of the individual in accordance with Section 17.
(c) the individual provided his consent for that purpose in accordance with PDPA.

(2) Eduwonka shall not —
(a) as a condition of providing a product or service, require an individual to consent to the collection, use or disclose of personal data about the individual beyond what is reasonable to provide the product or service to that individual; or
(b) obtain or attempt to obtain consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of the personal data, or using deceptive or misleading practices.
(3) Any consent given in any of the circumstances in subsection (2) is not validly given for the purposes of PDPA.
(4) In PDPA, references to the consent given, or demand to have been given, by an individual for the collection, use or disclosure of the personal data about the individual shall include consent given, or deemed to have been given, by any person validly acting on behalf of that individual for the collection, use or disclosure of such personal data.

4. Deemed consent
(1) An individual is deemed to consent to the collection, use or disclosure of personal data about the individual by Eduwonka for a purpose if —
(a) the individual, without actually giving consent referred to in Section 14, voluntarily provides the personal data to Eduwonka for that purpose; and
(b) it is reasonable that the individual would voluntarily provide the data.
(2) If an individual give, or is deemed to have given, consent to the disclosure of personal data about the individual by Eduwonka to another organization for a particular purpose, the individual is deemed to consent to the collection, use or disclosure of the personal data for that particular purpose by that other organization.

5. Withdrawal of Consent
(1) On giving reasonable notice to Eduwonka, an individual may at any time withdraw any consent given, or deemed to have been given under PDPA, in respect of the collection, use or disclosure of personal data about the individual for any purpose.
(2) On receipt of the notice referred to in subsection (1), Eduwonka shall inform the individual of the likely consequences of withdrawing his consent.
(3) Eduwonka shall not prohibit an individual from withdrawing his consent to the collection, use or disclosure of personal data about the individual, but this section shall not affect any legal consequences arising from such withdrawal.
(4) Subject to Section 25, if an individual withdraws consent to the collection, use or disclosure of personal data about the individual by Eduwonka for any purpose, Eduwonka shall cease (and cause its data intermediaries and agents to cease) collecting, using or disclosing the personal data, as the case may be, unless such collection, use or disclosure, as the case may be, without the consent of the individual is required or authorized under PDPA or other written law.

6. Collection, use and disclosure without consent
(1) Eduwonka may collect personal data about an individual, without consent or from a source other than the individual, only in the circumstances and subject to any condition in the Second schedule.
(2) Eduwonka may use personal data about an individual, without the consent of the individual, only in the circumstances and subject to any condition in the Third schedule.
(3) Eduwonka may disclose personal data about an individual, without the consent of the individual, only in the circumstances and subject to any condition in the Fourth schedule.

7. Access to personal data
(1) Subject to subsections (2) and (3) on request of an individual, Eduwonka shall, as soon as reasonably possible, provide the individual with —
(a) personal data about the individual that is in the possession or under the control of Eduwonka;
(b) information about the ways in which the personal data referred to in paragraph (a) has been or may have been used or disclosed by Eduwonka within a year before the date of the request.
(2) Eduwonka will not provide an individual with the individual’s personal data or other information under subsection (1) in respect to of the matters specified in the Fifth schedule.
(3) Eduwonka shall not provide an individual with the individual’s personal data or other information under subsection (1) if the provision of that personal data or other information, as the case may be, could reasonably be expected to —

(a) threaten the safety or physical or mental health of an individual other than the individual who made the request;
(b) cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
(c) reveal personal data about another individual;
(d) reveal the identity of an individual who has provided personal data about another individual and the other individual providing the personal data does not consent to the disclosure of his identity or (e) be contrary to the national interest

8. Correction of personal data
(1) An individual may request Eduwonka to correct an error or omission in the personal data about the individual that is in the possession or under the control of Eduwonka.
(2) Unless Eduwonka is satisfied on reasonable grounds that a correction should not be made, Eduwonka shall—
(a) correct the personal data as soon as practicable; and
(b) subject to subsection (3), send the corrected personal data to every other organization to which the personal data was disclosed by Eduwonka within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.
(3) Eduwonka may, if the individual consents, send the corrected personal data only to specific organizations to which the personal data was disclosed by Eduwonka within a year before the date the correction was made.

9. Accuracy of personal data
Eduwonka shall make a reasonable effort to ensure that personal data collected by or on behalf of Eduwonka is accurate and complete, if the personal data —

(a) is likely to be used by Eduwonka to make a decision that affects the individual to whom the personal data relates; or
(b) is likely to be disclosed by Eduwonka to another organization.

10. Protection of personal data
Eduwonka shall protect personal data in its possession or under its control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

11. Transfer of personal data outside Singapore
Eduwonka shall not transfer any personal data to a country or territory outside Singapore except in accordance with requirements prescribed under PDPA to ensure that Eduwonka provide a standard of protection to personal data so transferred that is comparable to the protection under PDPA.