1 – Introduction
At TJ Assurance Partners PAC (hereinafter referred to as "we," "us," or "our") we respect the privacy and confidentiality of the personal data of our clients, associates, and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
2 – How We Collect Your Personal Data
Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g., full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.
We collect your personal data in the following scenarios.
Human Resources (HR)
- When you apply for job positions through our recruitment process, whether as an employee, volunteer, or contractor
Sales
- When you make inquiries about our products or services, through website forms, emails, or customer support channels
Marketing
- When you interact with us through social media platforms, by following our pages, liking our posts, or engaging in direct messages (DMs)
IT & Data Security
- Through surveillance and security systems, such as CCTV monitoring within our premises or event locations
Legal & Compliance
- During the submission of corporate documents, personal information provided in the process of KYC (Know Your Customer) compliance, due diligence, or regulatory reporting,
- When you submit personal data as part of compliance with legal obligations (e.g., for tax purposes, statutory reporting, or regulatory filing)
3 – Types of Personal Data We Collect About You
The types of personal data we collect about you include the following.
Employment and HR-Related Activities
Personal Data collected for managing and administering employment relationships: Full Name, NRIC/FIN/Passport Number (Full or last four characters), Date of Birth, Nationality, Gender, Home Address, Personal Email Address, Phone Number (Mobile, Home), Marital Status, Job Title, Employment History, Salary Information, Bank Account Details (for salary disbursement), CPF (Central Provident Fund) Details, Work Permit Number, Professional Qualifications and Certifications, Performance Reviews and Feedback
Provision and Usage of Our Products and Services
Personal Data collected for the purpose of providing, improving, and facilitating customer interaction with our products and services:Full Name, NRIC/FIN/Passport Number (for verification or regulatory compliance), Date of Birth, Salary Information
Visitor and Communication Management
Personal Data collected for security, communication, and interaction with our premises or digital platforms: CCTV Footage (on-site surveillance)
4 – How We Use Your Personal Data
We use the personal data you provide us for one or more of the following purposes.
Service Delivery and Management:
- Rendering external audit services
Compliance and Legal Obligations:
- Ensuring compliance with legal, regulatory, and fiscal obligations, which may include auditing and reporting functions
Safety and Security:
- Ensuring the physical security of our premises, which may include the use of CCTV surveillance and visitor logs
Human Resources and Employment:
- Managing employment-related services such as payroll, benefits, and employee performance
5 – Who We Disclose Your Personal Data To
We disclose some of the personal data you provide us to the following entities or organisations in order to fulfil our services to you.
IT, Data, and Communication Services:
- Email Service Providers and EDM Vendors (e.g., Mailchimp, Constant Contact, ActiveCampaign)
Financial Institutions and Payment Processors:
- Banks and Financial Institutions (e.g., for transaction processing)
Government Agencies and Regulators:
- Regulatory Bodies (e.g., Personal Data Protection Commission, Monetary Authority of Singapore),
- Tax Authorities (for compliance with tax regulations),
- Immigration Authorities (e.g., Ministry of Manpower for work permit applications)
Health and Insurance Providers:
- Occupational Health Providers (e.g., for workplace health assessments)
Recruitment and Human Resources:
- Background Screening Providers (e.g., for reference checks, criminal record checks)
Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.
6 – How We Manage the Collection, Use and Disclosure of Your Personal Data
6.1 Obtaining Consent
Before we collect, use, or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g., when you apply for a job with us by sending in your resume/CV containing personal information.
We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to us are included):
- the personal data is publicly available;
- the personal data is disclosed by a public agency or disclosed to a public agency;
- the personal data is necessary for any investigation or proceedings;
- the personal data is necessary for evaluative purposes (e.g., determining the suitability of a job applicant for the job applied for);
- the personal data is necessary for the purpose of managing or terminating an employment relationship; and
- the personal data is necessary for a business asset transaction.
You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be in a position to process your job application, or business operation matters. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in the withdrawal clause below.
When you provide us with personal data of third parties such as referees, emergency contacts, or next-of-kin, you confirm that you have obtained their consent to disclose their personal data to us for the relevant purposes. You are also responsible for informing these individuals about our Privacy Policy and directing them to it for more information on how we handle personal data.
We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
- To respond to an emergency that threatens your life, health and safety or of another individual; and
- Necessary in the national interest, for any investigation or proceedings
6.2 Withdrawal of Consent
If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g., without your personal contact information we may not be able to inform you of future services offered by us.
Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service.
6.3 Use of Cookies
We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences.
The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.
Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.
You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.
6.4 Third-Party Consent
We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.
6.5 Exception
We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations
- To respond to an emergency that threatens your life, health and safety or of another individual; and
- Necessary in the national interest, for any investigation or proceedings
7 – How We Ensure the Accuracy of Your Personal Data
We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).
8 – How We Protect Your Personal Data
We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks.
We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.
9 – How We Retain Your Personal Data
We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.
We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.
10 – How You Can Access and Make Correction to Your Personal Data
You may write in to us to find out how we have been using or disclosing your personal data over the past year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.
If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date, you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.
11 – Transfer of Personal Data
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
12 – Mandatory Data Breach Notification
In the unlikely event that we suffer a data breach pertaining to unauthorised access or disclosure of personal data being stored or processed by us, we will meet the PDPA's breach notification timelines and requirements to perform the needful, including but not limited to informing relevant authorities and affected individuals, based on the Significant Harm or Significant Scale definitions as set out by the PDPA.
13 – Contacting Us
If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@tjassurance.com
Any query or complaint should include, at least, the following details:
- your full name and contact information; and
- brief description of your query or complaint.
We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.
14 – Changes to this Data Protection Notice
We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website.