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PRIVACY POLICY

The protection of personal information is important to Singapore Life Saving Society (SLSS).  SLSS is committed to respecting the right to privacy and the protection of personal information.

 

This document sets out:

  • what personal and sensitive information SLSS collects

  • how SLSS collects personal and sensitive information

  • how SLSS uses or discloses personal and sensitive information

  • how individuals can access or seek correction of information held by SLSS and

  • who to contact regarding privacy issues and complaints.

 

By providing your personal information to SLSS, you consent to its use, storage and disclosure in accordance with this Privacy Policy.

 

This Policy provides for the way in which Singapore Life Saving Society, its Affiliates and Associates may collect, use, store and disclose information.  Third party commercial entities and subsidiaries, whether owned or acting on behalf of SLSs or an affiliate or not, may be subject to the same privacy laws and may be governed by their own privacy policies.  SLSs will always do its utmost to ensure that personal information is respected and protected.

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What personal and sensitive information does SLSS collect?

 

Personal Information

Generally, personal information is information or an opinion (including information or an opinion forming part of a database) from which it is possible to determine someone’s identity.

The information collected by a SLSS about a particular person will vary depending on the circumstances of collection.  It may include, but is not limited to, a person’s contact details (name, email and/or postal address, phone number), date of birth, gender, credit card details, driver licence number, passport number, insurance details, employment history, qualifications or communication history with SLSS.

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Sensitive Information

Sensitive information is a type of personal information that also includes information or an opinion about:

  1. racial or ethnic origin

  2. political opinions

  3. membership of a political association, professional or trade association or trade union

  4. religious beliefs or affiliations or philosophical beliefs

  5. sexual preferences or practices

  6. criminal record; or

  7. health, genetic information or disability.

 

If it is reasonably necessary in the circumstances, SLSS may also collect sensitive information such as a person’s medical history, nationality, their ethnic background or disabilities.

SLSS is required by law to obtain consent when collecting sensitive information.  SLSS will assume consent to the collection of all sensitive information that is provided to it for use in accordance with this Privacy Policy, unless told otherwise.

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How does SLSS collect personal and sensitive information?

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Information may be collected when you:

  • become a member of a club, association or other body which is a member or affiliated with SLSS

  • subscribe to any publication of SLSS or an SLSS Affiliate, including electronic publications

  • provide details to SLSS or an SLSS Affiliate in an application form, consent form, survey, feedback form or incident report

  • enter personal information into, or agree to having your personal information entered into, one of SLSS’s online systems

  • access the SLSS website

  • contact SLSS via email, telephone or mail or engage with SLSS via social media

  • participate in any program, activity, competition or event run by SLSS or an SLSS Affiliate

  • purchase tickets to a sporting event from SLSS or an authorised agent

  • purchase merchandise, products or services from SLSS or an authorised agent or licensee

  • are elected or appointed to the Board or a committee of SLSS or an SLSS Affiliate

  • apply for employment or a volunteer position with SLSS or an SLSS Affiliate or

  • where SLSS is required to do so by law (for education, child protection, Work health and safety laws, charitable collections, Medical Treatment  or other legislation in Singapore).

 

Providing information

Depending on the circumstances, some types of information will be required and others might be optional. If you do not provide some or all of the information requested, this may affect SLSS’s ability to communicate with you or provide the requested products or services.

 

By not providing requested information, you may jeopardise your ability to participate in programs or competitions or apply for employment or volunteer positions with SLSS or an SLSS Affiliate.  If it is impracticable for SLSS to deal with you as a result of you not providing the requested information or consents, SLSS may refuse to do so.

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Collection from third parties

SLSS or an SLSS Affiliate may collect personal information regarding a child from the parent or other responsible person associated with that child.

 

In some circumstances, SLSS collects information from SLSS Affiliates or other third parties.

Examples of such third parties could include, without limitation, the Sports Singapore, the Singapore National Olympic Council, non-affiliated life saving organisations or government and law enforcement bodies.

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Information storage and protection

SLSS stores information in different ways, including in paper and electronic form. Much of the information we collect from and about our members is added to our ‘Surfguard’ database which is hosted by a third party data storage provider. When your information is entered into the Surfguard database, the information may be combined or linked with other information held about you.

 

Security of personal information is important to SLSS.  SLSS has taken steps to protect the information we hold from misuse, loss, unauthorised access, modification or disclosure. Some of the security measures SLSS uses includes strict confidentiality requirements of our employees, volunteers, SLSS Affiliates and service providers, as well as security measures for system access, and security measures for our website such as firewalls and system encryption.

 

SLSS is required to comply with the Personal Data Protection Act (PDPA). When SLSS has had a data breach that could result in serious harm, SLSS will notify the individual(s) that is/are affected. SLSS when notifying the individuals(s) and Personal Data Protection Council (PDPC), will also outline what steps will be undertaken in response to the breach. A review of the breach will be undertaken, and action(s) implemented to prevent a future breach.

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How does SLSS use and disclose personal and sensitive information?

 

Use

SLSS, and third parties to whom we may disclose personal information in accordance with this Privacy Policy, may use your personal information to:

  1. verify your identity

  2. complete background checks

  3. research, develop, run, administer and market competitions, programs, activities and other events relating to a variety of surf life saving sports and activities including but not limited to ‘Nippers’, ‘Rescue and Resuscitation’ events, Ironman and Ironwoman competitions, emergency management information, membership management, education offerings and organisation, social events, police or other legal agencies for the purposes of medical treatment amongst others

  4. research, develop and market products, services, merchandise and special offers made available by us and third parties

  5. respond to emergency situations involving or requiring medical treatment

  6. administer, manage and provide you with access to sls.com.au , ‘Surfguard’ database, self service portal and other IT based applications and

  7. keep you informed of news and information relating to various surf life saving events, activities and opportunities via various mediums.

 

SLSS may use health information to ensure that programs we operate are run safely and in accordance with any special health needs participants may require.  Health information may also be kept for insurance purposes. In addition, we may use de-identified health information and other sensitive information to carry out research, to prepare submissions to government or other regulatory bodies, or to plan events and activities.

 

Disclosure

SLSS may disclose your personal information to a range of organisations which include, but are not limited to:

  1. SLSS Affiliates and other organisations involved in surf life saving and emergency management

  2. companies we engage to carry out functions and activities on SLSS's behalf, including direct marketing

  3. our professional advisers, including our accountants, auditors and lawyers

  4. our insurers

  5. SLSS companies, subsidiaries and affiliates

  6. relevant sporting bodies such as the Sports Singapore,  Anti-Doping Singapore (ADS), Singapore National Olympic Council (SNOC), the Singapore National Paralympic Council (SNPC), various National Sporting bodies, and Ministries amongst others; and in other circumstances permitted by law.

 

In some circumstances, personal information may also be disclosed outside of Singapore. In such circumstances, SLSS will use its best endeavours to ensure such parties are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are suitably similar to the Singapore PDPA.

 

Any disclosure will be on such terms and conditions as SLSS determines taking into account the circumstances of the disclosure but always with the best interests of the parties whose personal information is being disclosed.

 

Direct marketing

SLSS will assume consent to use non-sensitive personal information to provide to you better services and marketing purposes (including disclosure of such information to service providers).

Every person whose data is collected by SLSS has the option to refuse e-mail, SMS or posted offers.  You may do this by updating the direct marketing settings in your user portal/Life Saving Online in SurfGuard, or via the opt-out procedures included in any communication from us (information relating to the option to unsubscribe from those communications may be retained).

If you are still not satisfied at the communication you are receiving, you can also write to SLSS’s Privacy Officer via the contact details set out below.

 

Other disclosures

In addition, SLSS may also disclose personal information:

  1. with your express or implied consent;

  2. when required or authorised by law;

  3. to an enforcement body when reasonably necessary; or

  4. to lessen or prevent a threat to an individual or public health or safety.

 

SLSS website

When users visit the SLSS website, our systems may record certain information about their use of the site, including the web pages visited and the time and date of their visit. SLSS uses this information to help analyse and improve the performance of the SLSS website.

 

In addition, we may use “cookies” on the SLSS website. Cookies are small text files that help a website to remember the preferences of users to improve the experience of using that website. In some cases, the cookies that we use may collect some personal information. SLSS will treat this information in the same way as other personal information we collect. You are free to disable cookies on your internet browser to prevent this information being collected; however, you may lose the benefit of an enhanced website experience that the use of cookies may offer.

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Websites linked to the SLSS website are not subject to SLSS’s privacy standards, policies or procedures.  SLSS does not take any responsibility for the collection, use, disclosure or security of any personal information that you provide to a third party website.

 

Accessing and seeking correction of information held by SLSS

SLSS will take all reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date. However, we rely on the accuracy of personal information as provided to us both directly and indirectly.

 

SLSS also relies on Affiliates and volunteers to enter data and make their best endeavours to ensure data is accurately recorded.

We encourage all users to regularly review and update their personal information on the Surfguard database and via the “members portal” link.

 

Individuals may also request access to their personal information held by us by making a request via the contact details set out below. We will respond to your request for access within 14 days and endeavour to provide the requested information within 30 days. If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will see that it is corrected.

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