Aims of the policy
Asia Pacific Hospice Palliative Care Network is a not-for-profit organization that needs to keep certain information on its employees, volunteers, members, supporters and trustees to carry out its day to day operations, to meet its objectives and to comply with legal obligations.
The organisation is committed to ensuring any personal data will be dealt with in line with the Personal Data Protection Act. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.
The aim of this policy is to ensure that everyone handling personal data is fully aware of the requirements and acts in accordance with data protection procedures. This document also highlights key data protection procedures within the organisation. This policy covers employed staff, trustees, volunteers and donors.
Definitions
In line with the Personal Data Protection Act principles, the Asia Pacific Hospice Palliative Care Network will ensure that personal data will:
- Be obtained fairly and lawfully and shall not be processed unless certain conditions are met
- Be obtained for a specific and lawful purpose
- Be adequate, relevant but not excessive
- Be accurate and kept up to date
- Not be held longer than necessary
- Be processed in accordance with the rights of data subjects
- Be subject to appropriate security measures
- Not to be transferred outside Singapore
The definition of ‘Processing’ is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computer.
The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. The organisation will seek to abide by this code in relation to all the personal data it processes, i.e.
- Accountability: those handling personal data follow publicised data principles to help gain public trust and safeguard personal data.
- Visibility: Data subjects should have access to the information about themselves that an organisation holds. This includes the right to have incorrect personal data corrected and to know who has had access to this data.
- Consent: The collection and use of personal data must be fair and lawful and in accordance with the PDPA’s data protection principles. Personal data should only be used for the purposes agreed by the data subject. If personal data is to be shared with a third party or used for another purpose, the data subject’s consent should be explicitly obtained.
- Access: Everyone should have the right to know the roles and groups of people within an organisation who have access to their personal data and who has used this data.
- Stewardship: Those collecting personal data have a duty of care to protect this data throughout the data life span.
Types of information processed
The Asia Pacific Hospice Palliative Care Network processes the following personal information:
- Members – Email, phone number, address, organisational position
- Supporters – Name, Address, Email
- Trustees – Name, Address, email, phone number
- Employees – Name, address, email, references
- Personal information is kept in the following forms:
- Electronic and paper
Groups of people within the organisation who will process personal information are employed staff.
Responsibilities
Under the Personal Data Protection Act, overall responsibility for personal data in a not-for-profit organisation rests with the governing body. In the case of the Asia Pacific Hospice Palliative Care Network, this is the board of trustees.
The governing body delegates tasks to the PDPA officer. The PDPA officer is responsible for:
- understanding and communicating obligations under the Act
- identifying potential problem areas or risks
- producing clear and effective procedures
- notifying and annually renewing notification to the Information Commissioner, plus notifying of any relevant interim changes
All staff, trustees and volunteers who process personal information must ensure they not only understand but also act in line with this policy and the data protection principles.
Breach of this policy will result in disciplinary proceedings.
Groups of people within the organisation who will process personal information are employed staff.
Policy implementation
To meet our responsibilities (staff, volunteers and trustees) will:
- Ensure any personal data is collected in a fair and lawful way;
- Explain why it is needed at the start;
- Ensure that only the minimum amount of information needed is collected and used;
- Ensure the information used is up to date and accurate;
- Review the length of time information is held;
- Ensure it is kept safely;
- Ensure the rights people have in relation to their personal data can be exercised
We will ensure that:
- Everyone managing and handling personal information is trained to do so.
- Anyone wanting to make enquiries about handling personal information, whether a member of staff, volunteer or service user, knows what to do;
- Any disclosure of personal data will be in line with our procedures.
- Queries about handling personal information will be dealt with swiftly and politely.
Training
Training and awareness raising about the Personal Data Protection Act and how it is followed in this organisation will take the following forms:
On induction: The data protection policy along with a briefing on how and where data is stored and considerations around sharing.
Awareness raising: Annual discussion on policy and reminder of responsibilities.
Gathering and checking information
Before personal information is collected, we will consider:
- What details are necessary for our purposes
- How long we are likely to need this information
We will inform people whose information is gathered about the following:
- why the information is being gathered
- what the information will be used for
- who will have access to their information (including third-parties)
We will take the following measures to ensure that personal information kept is accurate:
- send out reminders to people asking them to check their details on an annual basis
Personal sensitive information will not be used apart from the exact purpose for which permission was given.
Data security
The organisation will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:
- Setting up computer systems to allow restricted access to certain areas
- Back up of data on computers (onto a separate hard drive / onto tapes)
- Password protected attachments for sensitive personal information sent by email
Any unauthorised disclosure of personal data to a third party by an employee may result in disciplinary proceedings.
Subject access requests
Anyone whose personal information we process has the right to know:
- What information we hold and process on them
- How to gain access to this information
- How to keep it up to date
- What we are doing to comply with the Act.
They also have the right to prevent processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.
Individuals have a right under the Act to access certain personal data being kept about them on computer and certain files. Any person wishing to exercise this right should apply in writing to Mr Giam, Executive Director, APHN.
The following information will be required before access is granted:
- Full name and contact details of the person making the request
- their relationship with the organisation (former/ current member of staff, trustee or other volunteer, service user
- Any other relevant information- e.g. timescales involved
We may also require proof of identity before access is granted. The following forms of ID will be required:
- Copy of passport or birth certificate
Queries about handling personal information will be dealt with swiftly and politely.
We will aim to comply with requests for access to personal information as soon as possible but will ensure it is provided within the 40 days required by the Act from receiving the written request.
Review
This policy will be reviewed annually to ensure it remains up to date and compliant with the law.
Policy adopted: 1 April 2022
Reviewed: 1 April 2022
Next Review: 1 April 2023