PDPA Statement

The Perse School Singapore (TPSS) respects the privacy of individuals and recognizes the importance of the personal data you have entrusted to us. We believe it is our responsibility to properly manage, store, protect, process, and access the personal data of every current, former and prospective students’ and their parent/guardian’s, our employees, business partners (including agents and third party service providers) and any other individuals who have dealings with TPSS.

At TPSS, we are committed to adhering to the provisions and principles of the Personal Data Protection Act 2012. This Personal Data Protection Statement assists our community in understanding how we collect, use, and/or disclose personal data.

TPSS will collect, use, and disclose an individual’s 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 recognizes both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organizations to collect, use, or disclose personal data for legitimate and reasonable purposes.

The Act takes into account the following concepts:

  • Consent: Organizations may collect, use, or disclose personal data only with the individual’s knowledge and consent (with some exceptions).
  • Purpose: Organizations may collect, use, or disclose personal data in an appropriate manner for the circumstances and only if they have informed the individual of the purposes for the collection, use, or disclosure.
  • Reasonableness: Organizations may collect, use, or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances.

In line with these concepts, the Act contains ten main obligations which organizations are expected to comply with when engaging in activities related to the collection, use, and/or disclosure of personal data:

  • The Consent Obligation
  • The Purpose Limitation Obligation
  • The Notification Obligation
  • The Access and Correction Obligation
  • The Accuracy Obligation
  • The Protection Obligation
  • The Retention Limitation Obligation
  • The Transfer Limitation Obligation
  • The Data Breach Notification Obligation
  • The Data Portability Obligation

While TPSS will not delve into the details of these Obligations in this Personal Data Protection Statement, you can be assured that TPSS is constantly mindful of them in our collection, use, and disclosure of personal data.

For more detailed information, please refer to the Advisory Guidelines of the Personal Data Protection Commission at: https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act/Data-Protection-Obligations

1. Purpose for the Collection, Use & Disclosure of Personal Data

In general, subject to applicable exceptions permitted in the Act, before TPSS collects any personal data from our students, and their parent/guardian’s, our employees, business partners (including agents and third party service providers) and any other individuals who have dealings with TPSS, TPSS will notify all the abovementioned individuals of the purposes for which their personal data may be collected, used, and/or disclosed, as well as obtain consent for the collection, use, and/or disclosure of their personal data for the intended purpose.

Depending on the respective individual’s relationship with TPSS, the personal data collected may be used and/or disclosed for the following purposes:

For Students Generally

Most of our students will have consented to TPSS collecting, using or disclosing their personal data in the manner set out in the online matriculation form used when they first enrolled into TPSS; or when they use specific services and facilities offered by the school; or when their parents/guardians (on behalf of the students) are notified by the school administration of new rules and policies applicable to the student body, whereupon the students are deemed to have consented to TPSS collecting, using or disclosing their personal data.

For students who are 13 years of age or younger, TPSS shall obtain consent from the student’s parent or guardian in connection with the collection, use or disclosure of their personal data.

In addition to the express consent provided by the students and/or their parents/guardians through the online matriculation form / other avenues, the students and/or their parents/guardians consent that the personal data of the students may be used, collected and disclosed in the following manners:

  • Evaluating suitability for admission, enrolling, and providing educational courses and training, including sending materials on course/study/assignment/lecture and project materials, information on timetables, and examination/test details via various means, including postal mail, electronic mail, SMS or MMS, fax, and/or voice calls.
  • Administering and/or managing relationships with TPSS (including responding to inquiries, the mailing of correspondence, statements, or notices which could involve the disclosure of certain personal data to bring about delivery of the same).
  • 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 TPSS, including the obtaining of references and/or other information from prior admission of the student.
  • Processing applications for financial aid and administering and managing financial aid/grant/discounts and other support programs, which may include the use of personal data for development and disclosure of personal data to donors, grantors, external evaluators, and/or external organizations for purposes of assessment, periodic reports, event invitations, surveys, and/or publicity of TPSS-related programs.
  • Investigative purposes, including 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.
  • 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.
  • Carrying out market-related, evaluative, or similar research and analysis for TPSS’s operational strategy and policy planning purposes, including providing data to external parties for school program evaluation and to students’ former institutions of study and to partnering/affiliated institutions/centers for jointly administered programs.
  • Outreach and engagement to garner support and resources for TPSS, its community, and affiliated centers/institutions.
  • Supporting TPSS functions including but not restricted to, the teaching and personal and professional development of students, research, and administration of TPSS.
  • Processing and administering applications for inter-school/overseas exchange/transfer programs, ECAs, short courses, and other overseas activities and administering such programs, including disclosure of information to overseas institutions, companies, and training organizations.
  • Processing, administering, and conferring awards of prizes, medals, scholarships/sibling discounts, classes of honors, and other marks of distinction, and student or graduation status, and publication or releasing of information on the same.
  • Engaging Parent Committee (Parent School Association) including but not limited to notification on TPSS and committee-related initiatives and activities, an invitation to TPSS and committee-related events, updating of committee information, an invitation to participate in committee surveys, and sending of communication collaterals.
  • Processing applications and enrollment activities related to health, life, and travel insurance and service provision as well as school-related student support services and administering matters related to the use of these services (e.g., transportation and ECAs).
  • Facilitating participation in student life and community development opportunities, which may include social, cultural, athletic, and educational activities, events, volunteering, and training programs in clubs, societies, halls, and residences, and orientation/reception activities.
  • Taking of photographs and/or videos (whether by TPSS staff or third-party photographers and/or videographers) during events or seminars organized by TPSS or its affiliates for publicity purposes.
  • If consented to in the registration form and/or other methods of consent notification, providing marketing, advertising, and promotional information via postal mail, electronic mail, SMS or MMS, fax, and/or voice calls.
  • Any other purpose arising in respect of the environment within which an IB World School such as TPSS operates which is reasonable given your relationship with TPSS.
  • Any other purposes not related to those listed above or in the online matriculation form to which you consented, which TPSS may inform our students of in writing from time to time, but for which TPSS will seek our students’ parents/guardians separate consent.

There is deemed consent to the collection, use or disclosure of personal data about the students for a purpose not specifically informed to the students, if: 

  1. the student (or parent/guardian of the student, where applicable), without actually giving consent, voluntarily provides the personal data to TPSS for that purpose; and 
  2. it is reasonable that the student (or parent/guardian of the student, where applicable) would voluntarily provide the data

    For Employees/Staff Generally

    In order to comply with its contractual, statutory, and management obligations and responsibilities, TPSS is required to process personal data relating to its employees.

    All such data will be processed in accordance with the provisions of the Act and the relevant school’s rules and policies, including those on data protection, as may be amended from time to time. Our employees’ relationship with TPSS will, in almost all cases, be governed primarily by an employment contract, and our employees’ agreement to be bound by the Staff Handbook and/or Governance and Academic Policies Handbook (which may be revised from time to time), any of which will very often inform you expressly or impliedly the purposes for, and the manner in, which our employees’ personal data will be used.

    In addition to the express or deemed consent provided by the employees through any avenue, the list below serves to supplement and clarify various other avenues whereby the employees consent to their personal data being used, collected and disclosed, without limiting, superseding, or supplanting any express or implied terms in the abovementioned documents:

    1. Managing your employment relationship with TPSS.
    2. Using our employees’ bank account details to deposit salaries and other payments.
    3. Monitoring the use of TPSS’s computer network resources.
    4. Posting your photographs on TPSS’s intranet and website, staff pass, newsletters, and the like.
    5. Managing staff benefit schemes.
    6. Disclosing your personal data where necessary to external parties for purposes of school administration, and to Government agencies for official purposes, and disclosed to external third parties for, or in connection with, the above purposes, or where required by law.
    7. Any other purpose arising in respect of the environment within which an IB World School such as TPSS operates which is reasonable given your relationship with TPSS.
    8. Any other purposes not related to those listed above or in your employment contract, which TPSS may inform our employees of in writing from time to time, but for which TPSS will seek our employees’ separate consent.

    There is deemed consent to the collection, use or disclosure of personal data about the employees for a purpose not specifically informed to the employees, if: 

    1. the employees, without actually giving consent, voluntarily provide the personal data to TPSS for that purpose; and 
    2. it is reasonable that the employees would voluntarily provide the data

    For The Public and Other Third Parties Generally

    TPSS is committed to engaging and embracing its surrounding community, ecosystem, and society at large. As a result, TPSS often organizes activities in which external stakeholders or the general public are invited to participate.

    While it is impossible to list all the events in which TPSS hopes the public will participate, some events that you, as a member of the public, can look forward to include community outreach courses, exhibitions, roadshows (locally and/or internationally), extra-curricular activities, performances, and many others (Events).

    Naturally, in encouraging vibrant interaction with the public, there will be opportunities, and often a need, to collect, use, and/or disclose personal data from members of the public. Some of the reasons/purposes are as follows:

    1. .For security/verification purposes for certain Events. 
    2. For logistical/administrative purposes for certain Events (e.g., catering and transportation). 
    3. To keep our students/parents/guardians and employees updated on future TPSS Events/products which we feel may interest them. 
    4. For marketing/publicity purposes (e.g., photographs). 
    5. For any other purpose arising in respect of the environment within which an IB World School such as TPSS operates, which is reasonable given your relationship with TPSS.

    In almost all of the above situations, it will be entirely up to our students (parents/guardians) and employees as to whether, and to what extent, they wish to provide us with their personal data.

    For Events where such provision of personal data is a prerequisite to attendance, our students (parents/guardians) and employees shall be informed in advance so that they may make an informed decision as to whether to attend. TPSS will also endeavor at all times to inform our students (parents/guardians) and employees of the purposes for which personal data collected from them will be used, collected or disclosed.

    Should our students (parents/guardians) and employees at any time feel that the manner in which TPSS has acted, or seeks to act, in respect of the collection, use, or disclosure of personal data for an Event is inappropriate, please feel free to make their concerns known to the Principal of TPSS.

    2. Disclosure of Personal Data to Third Parties

    TPSS will not disclose our students’ (parents/guardians) and employees’ personal data to any third parties without first obtaining their consent, unless such disclosure is permitted under any of the statutory exemptions under the Act.

    In this respect, please note that TPSS may disclose our students’ (parents/guardians) and employees’ personal data to third parties in certain circumstances without first seeking their consent if such disclosure is either required or permitted under the Act, including without limitation, if the disclosure is required by law and/or regulations or if there is an emergency.

    3. Request for Access, Correction, and/or Withdrawal of Personal Data

    Subject to certain exceptions in the Act, our students (parents/guardians) and employees may request to access and/or correct the personal data currently in our possession or withdraw their consent for the collection, use, and disclosure of their personal data in TPSS’s possession at any time by submitting their request. TPSS shall first identify and verify that the individual requesting for access to the personal data is entitled to access such data. 

    For a request to access personal data, TPSS will provide our students (parents/guardians) and employees with the relevant personal data within a reasonable time from such a request being made, save for circumstances whereby we are prohibited from providing an individual access as stipulated by Section 21(3) of the Act or in any other provisions of the Act or under the applicable law. 

    For a request to correct personal data, TPSS will process their request, including undertaking necessary verification activities, as soon as practicable after the request has been made. TPSS will send the corrected personal data to every other organization to which the personal data was disclosed by TPSS within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose, or if our students (or parents/guardians of the students, where applicable), parents/guardians and employees so consent, only to specific organizations to which the personal data was disclosed by TPSS within a year before the date the correction was made.

    Our students (or parents/guardians of the students, where applicable), parents/guardians and employees may be charged a reasonable fee for the handling and processing of their requests to access and/or correct their personal data, but they will be notified in advance of such costs.

    For a request to withdraw consent, TPSS will process the request within a reasonable time from the request being made. In some cases, requests for withdrawal of consent may adversely impact our students’, parents/guardians, and employees’ relationship with TPSS, as it may hinder TPSS’s ability to continue to interact with them. TPSS will notify our students, parents/guardians, and employees in advance of such impact, if any.

    4. Administration and Management of Personal Data

    TPSS will take appropriate measures and make a reasonable effort to keep our students’ (parents/guardians’) and employees’ personal data accurate, complete, and updated, especially if the personal data is (a) likely to be used by TPSS to make a decision that affects the abovementioned individuals to whom the personal data relates; or (b) is likely to be disclosed by the organisation to another organisation. 

    TPSS will also take reasonable efforts to ensure that our students’ (parents/guardians’) and employees’ personal data is adequately protected and secured. TPSS will make reasonable and appropriate security arrangements will be taken to prevent unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage, and/or alteration of personal data, including but not limited to 

    1. requiring all employees to be bound by confidentiality obligations in their employment agreements; 
    2. implementing robust staff policies and procedures regarding confidentiality obligations; and
    3. restricting access to personal data on a need-to-know basis etc. 

    TPSS will also cease to retain such personal data and ensure that the personal data in our possession or under our control is destroyed as soon as it is reasonable to assume that: 

    1. The purpose for which that personal data was collected is no longer being served by the retention of such personal data. 
    2. Retention is no longer necessary for any other legal or business purposes.

    TPSS websites may contain links to other websites not maintained by TPSS. Such third-party websites are subject to their own data protection and privacy practices, and our students (parents/guardians) and employees are encouraged to examine the data protection policies of those websites.

    5. Responsibility of EMPLOYEES (Staff, Department), STUDENTS, AND OTHER STAKEHOLDERS

    The Act also imposes certain responsibilities on all those who process personal data at the school, whether you are a member of staff holding, using, and sharing personal data in your teaching, research, or administration, or a student accessing and recording personal data in your studies or other activities.

    These obligations include holding and using data in a secure manner, making sure that data is handled in line with what individuals have been told, having appropriate arrangements in place for the access to (and sharing of) data, and making sure that individuals’ data is accurate and retained for a suitable period.

    If a data breach occurs (e.g., personal data held by the school is lost, stolen, inadvertently disclosed to an external party, or accidentally published), this should be reported immediately to your seniors and the Principal of TPSS so that TPSS may review the circumstances and liaise as necessary with colleagues internally and the relevant external authorities.

    The Data Protection Officer can be reached at contact@perse.com.sg