In this Personal Data Protection Policy (“Privacy Policy”), the words “School”, “SSP”, “we”, “our” and “us” refer to the Singapore Sports School located at 1 Champions Way, Singapore 737913.

Background

In view of the enactment of the Personal Data Protection Act 2012 (“PDPA”), including all the amendments, regulations and notifications made thereunder, SSP has put in place a personal data protection policy in relation to the collection, use and disclosure of prospective, current and/or past student (“Student”)’s and/or parent/guardians’ personal data in Students’ and/or parent/guardians’ dealings with SSP. This Privacy Policy applies to personal data in SSP’s possession or under SSP’s control, including personal data in the possession of organisations which SSP has engaged to collect, use, disclose or process for our purposes. For the purposes of this Privacy Policy, a reference to “Student” includes “child” and “ward”, and where applicable, to “children” and “wards”; and a reference to “parent(s)” includes “guardian(s)”.

From time to time, it may be necessary for Students and/or parents to supply SSP with personal data about Students and/or parents and other individuals for purposes in connection with Student’s enrolment in SSP.

In this Privacy Policy, “personal data” means information about Students and/or parents, whether true or not, who can be identified: (a) from that data; or (b) from that data and other information to which SSP has or is likely to have access. Such personal data may obtained from Student applications and documents and any other personal information voluntarily provided by Students and/or parents and processed by us.

Some examples of personal data about Students and/or parents which SSP may collect include the following (without limitation): name, age, citizenship, identification number, academic status and results, sport achievements, medical and disability information, residential address, mobile and residential telephone number, personal email address, bank account, photograph or video image and etc.

Collection And Use Of Personal Data

We generally do not collect Student/parents’ personal data unless (a) it is provided to us voluntarily by Student/parents or via a third party who has been duly authorised by such Student/parents to disclose your personal data (your “authorised representative”) directly after (i) Student/parents have been notified of the purposes for which the data is collected, and (ii) Student/parents have provided consent (express, implied or deemed) to the collection, use and/or disclosure of Student/parents’ personal data for those purposes, or (b) collection, use and/or disclosure of Student/parents’ personal data without consent is permitted or required by the PDPA or any other law(s). We will seek your consent before collecting any additional personal data and before using Student/parent’s personal data for a purpose which has not been notified to you (except where permitted or authorised by law). To avoid doubt, where our purposes of obtaining personal data is for direct marketing messages, we will obtain express consent from you, which will be obtained through the opt-in method.

Purpose

In accordance with our obligations under the PDPA, SSP will only collect, use and/or disclose your personal data for purposes that a reasonable person would consider appropriate in the circumstances and that you have been informed of (where applicable).

SSP will/may collect, use, disclose and/or process Students’ and/or parents’ personal data for one or more of the following purposes:

(a) Processing Students’ admission application with us;

(b) Administering, processing and/or managing Students’ application(s) for awards, scholarship (whether such award or scholarship is provided by the School or any third party) and/or financial assistance, grants or bursaries, and if successful, administering and/or managing Students’ awards, scholarships and/or financial assistance, grants or bursaries;

(c) Supporting and/or dealing with Students’ studies, trainings, competitions, health, medical needs, safety and welfare requirements such as (but not limited to) student support services, counseling, careers advices and health services;

(d) Planning and implementing appropriate training programmes for Students;

(e) Measuring and keeping track of Students’ progress at SSP;

(f) Administering and/or managing activities organised and/or held by SSP. Please note that photographs(s) or video images of Students and/or parents may be taken during such activities and used, disclosed, processed and published in materials such as newsletters or other publications, yearbooks or any materials/books and you hereby agree to the same;

(g) Administering and/or managing the use of facilities including but not limited to Students’ accommodation needs, provision of Information Technology services and recreation facilities;

(h) Contacting Students and/or parents via different modes such as phone/voice call, short text message, email and/or postal mail for School related matters such as but not limited to School terms and events, studies, training and competition arrangement, fees and boarding and communicating with Students and/or parents in the event of public transport disruptions, emergencies or other extraneous circumstances such as national disasters, health pandemics, fire drills, evacuation drills and etc.;

(i) Carrying out background checks, investigation and screen activities in accordance with legal or regulatory obligations that may be required by the Singapore law or that may have been put in place by us;

(j) Dealing with complaints related matters;

(k) Conducting disciplinary and security matters and/or arrangements. Please be informed that there are surveillance cameras installed in SSP for security reasons; (l) Producing statistics and research for internal and/or statutory reporting and/or record keeping requirements and performing SSP policy/process reviews;

(m) Carrying out research, analysis and development activities, including but not limited to data analytics, surveys and/or profiling to improve any of the School’s programs in sport, academic, boarding, support services and etc.;

(n) Responding to requests for information from local hospitals, embassies, public agencies, ministries, statutory boards or similar authorities;

(o) Complying with any government or regulatory requirements of any relevant jurisdiction to make disclosure;

(p) Maintaining and promoting Students’ alumnus relationship with us by informing Students and/or parents, of activities including, but not limited to, events and updates to the School’s development by phone/voice call, short text message, email and/or postal mail and by providing Students and/or parents with SSP’s publications that are for alumni purposes;

(q) Conducting publicity and/or the development of promotional materials to showcase and market Students’ achievements as a student and/or alumnus of SSP, publishing Students’ and/or parents’ image(s) and/or personal data on public media platforms. Students and/or parents hereby grant SSP permissions to use their name, photograph, video images, personal story and information Students/parents provide to SSP in the School’s promotional materials; and

(r) To contact Students/parents for fund raising activities for School selected causes by various modes of communication platforms including but not limited to phone/voice call, short text message, email, social media and/or postal mail.

The purposes listed in the above clauses may continue to apply even in situations where Students’ enrolment with SSP has been terminated or altered in any way, and for a reasonable period thereafter (including, where applicable, a period to enable SSP to enforce its rights under any contract with Students).

Athlete Development And Performance Support

In respect of Athlete Development and Performance Support (“Support Services”), all such personal data, including (but not limited to) records, recordings of consultations, photography and videography of training and competition, will be done in strict confidence (where applicable), and access will be restricted to directly relevant personnel (e.g. sport scientist, coach(es), General Manager) and senior SSP management. All other relevant personnel will be informed on a need-to-know basis only. Students will be informed prior to any Support Services being conducted, and consent for any potential disclosure of personal data shall be in accordance with this Privacy Policy.

The findings obtained from the Support Services will be shared with Students’ coach(es).

As part of continual learning and sharing of information, SSP/NYSI may present the findings at conferences and public in journals so that other interested people may learn from our findings. In such instances, clearance from an institutional review board would be sought. In these instances, due care will be taken to ensure that all data is anonymised and that no personal data will be disclosed.

Disclosure To Third Parties

The School may be required to disclose Students’ and/or parents’ personal data to third parties which would be processing Students’ and/or parents’ personal data for one or more of the above purposes. These third parties include but are not limited to the following:

(a) Organisations including (without limitation) National Sport Associations with which we are collaborating for one (1) or more of the abovementioned purposes;

(b) Individuals, Organisations, Universities and/or any Government Agency/Authority who have provided Students with scholarships, financial assistance, awards, medals or prizes during the period of Students’ studies in SSP and/or who may request for information relating to Students’ progress and result as a Student in SSP;

(c) Any service providers engaged by the School who process Students’ personal data on behalf of the School including, but not limited to, hospitals, medical centre(s), Outward Bound Singapore and those which supply administrative services to the School such as manufactures of award medals, plagues, trophies, information technology companies and printers of the School publications; and

(d) Organisations and/or educational institutions which are involved in exchange programmes with us.

We may/would not be able to process Students with us for a place and/or financial assistance, grants and/or bursaries whether they are from us or external organisatons should Students/parents fail to supply us with certain personal data. Likewise, the School may/would not be able to effectively administer our relationship with Students and/or parents.

Unless otherwise permitted under the PDPA, the School will not disclose Students’ and/or parents’ personal data to any extent, which we will determine in good faith, to be greater than necessary.

Withdrawing Consent By Student And/Or Parents

The consent that Students/parents provide for the collection, use and disclosure of Students’ and/or parents’ personal data will remain valid until such time it is being withdrawn by you in writing. Student/Parents may withdraw consent (in part or in whole) and request SSP to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to SSP’s Data Protection Officer.

Upon receipt of Student/parents’ written request to withdraw consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with the relevant Student and/or parent) for the request to be processed and, if necessary, for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect the relevant Student’s and/or parent’s rights and liabilities to us. In general, we shall seek to process such requests within ten (10) business days of receiving it.

Withdrawal of consent does not affect SSP’s right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Access To And Correction Of Personal Data

Students/Parents have the right to request access to, update and/or correct their personal data held by us. If you wish to make (a) an access request for access to a copy of the personal data which SSP holds about you or information about the ways in which SSP uses or discloses your personal data, or (b) a correction request to correct or update any of your personal data which SSP holds, you may submit your request in writing or via email to SSP’s Data Protection Officer.

A fee may be charged for an access request. We will inform you of the fee before processing the request. Depending on the request that is being made, SSP will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents (or systems) themselves.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so.

Where we are not required to provide you with any personal data or make a correction requested by you under the PDPA, any such request for the same shall be refused. In such situations, and in accordance with our obligations under the PDPA, we will preserve, for not less than 30 days after the date of refusal or such other prescribed period, a copy of the personal data concerned. Such copy of the personal data concerned shall be a complete and accurate copy of the personal data concerned.

Protection Of Personal Data

To safeguard Students’/parents’ personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures 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 providers and agents only on a need-to-know basis.

Students/Parents should be aware, however, 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.

Accuracy of Personal Data

SSP generally relies on personal data provided by Students/parents (or your authorised representatives). In order to ensure that the personal data is current, complete and accurate, you should inform the Academic Admin Team of any changes to your personal data in writing.

Retention Of Personal Data

SSP may retain Students’ and/or parents’ personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

SSP will cease to retain Students’/parents’ personal data as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes. At such point in time, SSP will either cease to retain the documents containing personal data or we may remove the means by which the personal data may be associated with particular individuals (that is, to anonymise the data). In the latter case, SSP will take steps to minimise the risks of re-identification of the individual involved.

Transfer Of Personal Data Outside Singapore

We generally do not transfer personal data to countries outside of Singapore. However, if we do so, we will obtain Student’s and/or parent’s consent for the transfer to be made and we will take steps to ensure that such personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

Data Breach Notification

In the unlikely event that SSP suffers a Data Breach (defined below) in relation to personal data, SSP will assess whether the Data Breach is notifiable, and notify the affected individuals and/or the Personal Data Protection Commission (“PDPC”) where it is assessed to be notifiable. To be clear, a Data Breach within SSP does not trigger any obligation to notify affected individuals and/or the PDPC.

For the purposes of this section, “Data Breach” in relation to personal data means (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of personal data; or (b) the loss of any storage medium or device on which personal data is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal data is likely to occur.

Effect Of Policy And Changes To Policy

From time to time, we may update this Privacy Policy without any prior notice to ensure that our Privacy Policy is consistent with regulatory changes. Should any revision(s) be made to this Privacy Policy, updates will be published on our public site. Subject to your legal rights in Singapore, the prevailing terms of the Privacy Policy shall apply.

This Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Privacy Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.

Queries

If students/parents have any questions relating to our collection, use, disclosure and/or process of your personal data or the matters set out in this document, please contact our Data Protection Officer.

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