DATA PROTECTION POLICY FOR RESPONDENTS
This Data Protection Policy (“Policy”) sets out the basis upon which LHL Market Research Support Pte Ltd (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of respondents in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
APPLICATION OF THIS POLICY
1. This Policy applies to all persons who have willingly signed up as a research respondent with us.
2. We collect your personal data through the following methods:
- Telephone Interviews
Face to Face Interviews
Respondent Application Form
Qualitative Studies (Focus Groups, In-depth Interview)
3. We use the personal data we have collected for the following purposes:
- Recruitment and selection for relevant studies
Respond to queries and feedback
Investigation of complaints
Internal purposes: audits, data analysis, research
4. The types of personal data we collect about you:
- Contact information
Photo and video
1. As used in this Policy, “personal data” means data, whether true or not, about a respondent who can be identified:
(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.
2. Personal data which we collect may include, without limitation, your:
(a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
(b) mailing address, telephone numbers, email address and other contact details;
(c) employment status;
(d) photographs and other audio-visual information;
(e) written or verbal responses within the survey setting
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally collect personal data that (a) you knowingly and voluntarily provide, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your project recruiters), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written or verbal consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
WITHDRAWING CONSENT BY RESPONDENTS
5. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. If you are a respondent who has not participated in any of our market research studies, you may withdraw consent and request us to stop 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 our Data Protection Officer at the contact details provided below.
6. Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and put your request into effect within 60 days of receiving it.
7. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your respondent application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 5 above.
8. Please note that withdrawing consent does not affect our 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
9. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to us with the contact details provided.
10. A reasonable time frame should be set, and there should not be any unjustified delay in effecting the withdrawal request. Generally, as a rough gauge, the time frame to be indicated should stay within 30 days of the withdrawal request.
PROTECTION OF PERSONAL DATA
11. To safeguard your 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.
12. You 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
13. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
14. We may retain your 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.
15. We will cease to retain your personal data or remove the means by which the data can be associated with you, 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
16. 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 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.
EFFECT OF POLICY AND CHANGES TO POLICY
17. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
18. 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 Notice was last updated. Your continued participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.
CONSENT CLAUSE FOR RESPONDENTS
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, via this address:
Effective date: 1 November 2018
Last updated: 1 November 2018