We will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2012 (“Act”). The Act establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
The Act takes into account the following concepts:
- Consent Organisations may collect, use or disclose personal data only with the individual’s knowledge and consent (with some exceptions);
- Purpose Organisations may collect, use or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use or disclosure; and
- Reasonableness Organisations may collect, use or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances.
In projecting the three main concepts above, the Act contains nine main obligations which organisations are expected to comply with if they undertake activities related to the collection, use and/or disclosure of personal data:
(1) The Consent Obligation
(2) The Purpose Limiting Obligation
(3) The Notification Obligation
(4) The Access and Correction Obligation
(5) The Accuracy Obligation
(6) The Protection Obligation
(7) The Retention Limitation Obligation
(8) The Transfer Limitation Obligation
(9) The Openness Obligation
While we will not be going into the details of these Obligations in this Personal Data Protection Statement, you can be rest assured that we are constantly mindful of them in our collection, use and disclosure of personal data. Should you wish to know more about these obligations, an excellent summary can be found in the Advisory Guidelines of the Personal Data Protection Commission at:
If you have any questions on this policy or in relation to how Sorbonne-Assas International Law School Asia manages, protects and/or processes your personal data, please contact our Data Protection Officer (the “DPO”) via email: firstname.lastname@example.org
Purpose for the Collection, Use & Disclosure of Personal Data
Depending on your relationship with Sorbonne-Assas International Law School Asia (whether as a student, alumnus, staff, vendor or service provider, etc.), the personal data which we collect from you may be used and/or disclosed for the following purposes:
a) For maintaining student records
b) For school communications
c) For audit, administration and emergency purposes
d) For emergency contact
e) Evaluating suitability of admission or employment
f) Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by Sorbonne-Assas International Law School Asia, including the obtaining of references and/or other information from prior educational institutions and employers.
g) Processing application(s) for scholarships and administering and managing scholarship and other support programmes, which may include disclosure of personal data to donors, external evaluators and/or external organizations for purposes of periodic reports, event invitations, surveys and/or publicity of Sorbonne -Assas International Law School Asia related programs.
h) Monitoring the use of Sorbonne-Assas International Law School Asia’s computer network resources, including emails and internet usage with Sorbonne -Assas International Law School Asia email accounts, portals.
i) Investigating possible fraud, misconduct, unlawful action or omission, and utilizing electronic access and video systems to maintain campus security of persons or property, control access and investigate suspicious or inappropriate activities
j) Responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorized to carry out specific Government services or duties
k) Supporting Sorbonne -Assas International Law School Asia functions including, but not restricted to, the teaching and personal and professional development of students and administration of Sorbonne -Assas International Law School Asia.
l) Processing and administering applications for overseas exchange programmes and other overseas activities.
m) Processing, administering and conferring awards of prizes, medals, scholarships, and other marks of distinction, and student or graduation status, and publication or releasing of information on the same.
n) Processing applications and enrolment activities related to health, life and travel insurance and service provision as well as school-related cards, and administering matters related to use of those services.
o) Taking photographs and/or videos (whether by Sorbonne -Assas International Law School Asia stuff or third party photographers and/or videographers) during events organized by Sorbonne Assas International Law School Asia.
p) Any other purposes which Sorbonne -Assas International Law School Asia may inform you in writing from time to time, but for which Sorbonne -Assas International Law School Asia willÂ seek your separate consent.
Disclosure of Personal Data to Third Parties Disclosure Permitted by Statutory Exemption under the Act
In order to conduct our operations more smoothly, Sorbonne-Assas International Law School Asia may disclose your personal data to our third party service providers, and affiliates or related corporations. This is because such third parties would be processing your personal data on Sorbonne-Assas International Law School Asia’s behalf for the purposes mentioned above.
Sorbonne-Assas International Law School Asia will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act, e.g.
- the disclosure is required by law; or is necessary for any investigation or proceedings
- the purpose of such disclosure is clearly in your interests and consent cannot be obtained in a timely way;
- the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual.
For an exhaustive list of exceptions, you are encourage to purse the PDPA which is publicly available atÂ http://statutes.agc.gov.sg.
Request for Access, Correction and/or Withdrawal of Personal Data
Subject to certain exceptions in the Act, you may request to review and update the personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession. Please submit your request to email@example.com.
For a request to access your personal information, we will ask you to verify your identity and specify what information you wish to access. Sorbonne-Assas International Law School Asia will provide you with the relevant personal data within a reasonable time after the request has been made.
For a request to correct your personal data, Sorbonne-Assas International Law School Asia will correct your personal data as soon as practicable after verifying your identity. We will send the corrected personal data to every other organisation to which the personal data was disclosed by Sorbonne-Assas International Law School Asia within a year before the date the correction was made, unless that other organisation does not need the corrected personal data, or if you so consent, only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
Sorbonne-Assas International Law School Asia will similarly process your request within a reasonable time after a request to withdraw consent has been made. In some cases, the request to withdraw consent may adversely impact your relationship with Sorbonne-Assas International Law School Asia. We will notify you in advance of any such impact.
Administration and Management of Personal Data
Sorbonne-Assas International Law School Asia will take appropriate measures to keep your personal data accurate, complete and updated.
We will also take reasonable efforts to take appropriate preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be put in place to prevent any unauthorised access or misuse of your personal data.
We will similarly take reasonable efforts to ensure that the personal data in our possession is destroyed as soon as (i) the purpose for which that personal data was collected is no longer being served by the retention of such data; and (ii) retention is no longer necessary for any other legal or business purposes.
As part of our effort to ensure that we properly manage, protect and process your personal data, we will be continually reviewing our policies, procedures and processes.
We may amend the terms of this Personal Data Protection Statement & Privacy Statement at our absolute discretion. We recommend that you check our website from time to time to remain updated as to any changes in our personal data policy or any other policies.
Last updated: January 2015