Personal Data Protection Policy

By using the services of Bishan-Toa Payoh Town Council (the "Town Council"), you signify that you have read, understood, and agree to the Town Council's collection, use, and disclosure of your personal data as described in relevant portions of this Policy.

We will uphold your trust in us by protecting and responsibly using your personal data while working with key government agencies and our community partners to improve our customer service for municipal services. Together, we aim to improve the living environment of our estates.

1) Information we may collect from you

The Town Council may collect the following data about you either directly from you, or from your authorized representatives (i.e., persons whom you have authorized and persons who have been validly identified as being you or your authorized representative), from third parties (including government or public agencies), or publicly available sources:

• Personal information (such as your full name, NRIC, telephone number(s), address and email address);
• Records from correspondences, including details obtained through your calls or emails, your feedback via our website, your payment-related information or otherwise, your participation in our quizzes, surveys, or polls - e.g., votes on Neighbourhood Renewal Programme (NRP), Repair & Redecoration Programme (R&R); through interaction with our staff etc ;
• Your photographs and/or video images taken at Town Council events or via CCTVs at Town Council offices or common areas managed and maintained by the Town Council (e.g., lifts);
• Information derived from cookies (small text files which uniquely identify your browser) where you visit any website or use any application created by or on behalf of the Town Council; and/or
• information you provide to the Town Council concerning the provision of any services from the Town Council to you (e.g., your application to use Town Council's facilities, your request for bulky item removal services, your request to be alerted on estate matters via SMS-Alert service).

2) How do we collect your Personal Data?

Any personal information held by us will be committed to a high degree of protection. Here are the ways that we collect your data – through these touchpoints which are relevant to how you may interact with us:

• contact us at our hotline or via email;;
• submit feedback via our QR code(s) or MSO One Service app;
• interact with our staff;
• use our services, such as bulky items removal service, SMS-Alert, the Town Council feedback channel;
• participate in polling exercises, such as NRP, R&R;
• making payments;
• booking of common facilities (e.g. void deck, open space, common property etc.);
• advertise on newsletters;
• attend our events;
• authorize your representatives or third parties (including government or public agencies, such as HDB, NEA) to interact with us on your behalf;
• visit our website;
• procurement of tender documents;
• submit your Personal Data to us for any other reason.

3) Use and disclosure of personal data collected

You agree that the Town Council may use your personal data where permitted by applicable Law and for the following purposes:

3.1 Service & Conservancy Charges

(a) to facilitate the collection of service & conservancy charges ("S&CC"), the refund of any excess charges, and/or the transfer of credit balance to designated account(s);
(b) for the setting up and/or termination of recurring S&CC payment arrangements with financial institutions and banks (such as Interbank GIRO deduction or credit card monthly payments); and
(c) for the processing and collection of penalty fees, legal fees and/or disbursement fees in connection with late S&CC payments;

3.2 Collection of mortgage instalment & rental on behalf of Housing & Development Board

(a) This is to facilitate the collection of mortgage instalment and rentals on behalf of the Housing & Development Board;

3.3 Booking of facilities

(a) for purposes of processing your application to use common facilities (e.g. void deck, open space, common property etc.), including evaluation of your application and the purpose of use, and contacting you in connection therewith; and
(b) (b) for administration purposes upon grant of permit, including the issuance of permit, collection of payments, inspection of facilities after use, refund of deposit, and processing any cancellations;

3.4 Other services (e.g. bulky item removal).

This is for the purposes of administering your request for Town Council services (such as bulky item removal service), including the evaluation of your request, and contacting you in connection therewith;

3.5 Financial assistance and/or S&CC instalment payment plan

(a) for purposes of processing your application for financial assistance and/or S&CC instalment payment plans, including evaluation of your suitability, contacting you in connection therewith, preparation of assessment reports, application to public agencies for financial assistance schemes, and conduct of means test; and
(b) for disbursement of funds and/or administration of S&CC instalment payment plan upon approval;

3.6 Surveys and polls (e.g. Neighbourhood Renewal Programme, residents' satisfaction surveys)

(a) to collate and analyse your preferences on improvement works in the neighbourhood (such as support for such works, preference on type of improvement works, colour schemes etc.); and
(b) to collate and analyse your satisfaction levels (ratings or otherwise) on the Town Council's provision of services and performance of works;

3.7 Enquiries or feedback

(a) to provide you with information as requested and/or to respond to your enquiries;
(b) to compile and analyse your feedback for internal use; and
(c) to contact you to request for more information where required;

3.8 SMS-Alerts: This is to facilitate the Town Council in sending announcements, alerts and/or updates relating to estate matters via SMS;

3.9 Quiz: to facilitate and administer quizzes, including announcement of winner(s), notification to collect prizes, gifts or vouchers;

3.10 Photographs and video images taken at Town Council events: for use in the Town Council's corporate publications, and informational and communications materials;

3.11 Photographs and video images taken via CCTV at Town Council offices orcommon areas: for safety and security purposes;

3.12 General

In addition, you agree that the Town Council may disclose your personal data where permitted by applicable Law and for the following purposes:

• if we are under a duty to disclose or share your personal data:
  (a) where we believe that we are under a legal obligation to disclose; or
  (b) to protect the rights, property, security, or safety of the Town Council, residents, premises, or others;
• to disclose to public agencies (such as Housing & Development Board, Community Development Councils, and National Environment Agency) for funding, reporting, statistical, research, survey, and follow-up purposes, as the case may be;
• to persons who have been validly identified as being you or your authorised representative(s) pursuant, for the purpose of the relevant transaction or enquiry;
• to your authorized proxies, such as your Member of Parliament or a social welfare organization representing you; and/or
• to third parties with whom we have contracted to provide services for any of the purposes described above. Where the Town Council discloses your personal data to external/third parties, the Town Council shall ensure that such data is used only to provide services to the Town Council.

4) Information Security, Data Storage and its applicability to External Parties

The Town Council will uphold the necessary security controls to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar activities to protect your personal data.
The same data protection standards are to be imposed on external/third parties (our contractors or vendors) who provide services to the Town Council, but the town council cannot assume any responsibility for any actions or omissions on their part.

• The data we collect from you may be transferred to, processed, and stored at, our offices or our service providers' offices in Singapore or overseas. The Town Council will take all steps as required by mandatory Singapore law in connection with any transfer of such data overseas.
• The Town Council will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar activities to protect your personal data in the Town Council's possession or under the Town Council's control.
• The Town Council will require these data protection standards to be observed by external parties who provide services to the Town Council and/or to whom we disclose your personal data, but we cannot and do not assume any responsibility for any actions or omissions of external/third parties.

5) Cookies and Third Party Sites

5.1 When accessing the Town Council's website, there could be cookies that track visitors via their IP addresses together with dates and times of access. This information is purely used to analyze trends, administer the site, track users' movement and gather broad demographic information for internal use. IP addresses are not linked to personally identifiable information.

5.2 You can delete cookies already stored on your computer; for example:

• in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
• in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
• in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.

5.3 The Town Council's website may include links to other websites operated by third parties for your use and reference, but we are not responsible for the privacy practices of others. We would encourage you to check/learn about their privacy policies.

6) Withdrawal of Consent and Requests for Access, Correction of Personal Data

Please note that with the withdrawal of consent to any or for all use or disclosure of Personal Data, depending on the nature of the request, Town Council may not be in a position to continue to provide the services or administer any contractual relationship that is in place. Such withdrawal may also result in the termination of any agreement or arrangement with the Town Council.

• At your request, we would provide access to your personal data, save that in specified circumstances, your access may be subject to fees to meet our costs.
• You may withdraw consent or request to access and/or correct your Personal Data currently in Town Council's possession. Town Council has the right to charge a reasonable fee for processing access and/or correction requests.
• Please contact our Data Protection Officer (DPO) via email at prm@btptc.org.sg if you would like to apply for access/correction of your own personal data or if you would like us to cease use of your personal data for any purpose, and we will provide the relevant application form to you.

7) Amendments to this Personal Data Protection Policy

To ensure that Town Council appropriately manages, protects, and processes your Personal Data in compliance with the PDPA, we will review our policies, procedures and processes relating to personal data protection.
The Town Council may update this Personal Data Protection Policy from time to time to ensure it is consistent with any legal or regulatory requirements changes. Town Council reserves the right to revise the terms of this Policy at our discretion without prior notice to you, according to such review.

8) Governing Law

This Privacy Policy shall be governed in all respects by the laws of Singapore.

9) Contacting Us

For any questions, feedback, or suggestions regarding this Policy or more information about Town Council's data protection policies and practices, don't hesitate to contact our Data Protection Officer via email prm@btptc.org.sg

We will try to respond to your question or request promptly. We may, however, depending on the nature of the question or request, need up to 30 working days to provide you an estimate of when we will be able to respond to you.