We are Institute for Human Resource Professionals (“IHRP” or as appropriate in the context, “we”; “us”; or “our”). Institute for Human Resource Professionals is the Human Resource (HR) professional body, set up by the tripartite partners: the Ministry of Manpower (MOM), the National Trades Union Congress (NTUC) and Singapore National Employers Federation (SNEF) to professionalize and strengthen the HR practice in Singapore. IHRP is the only HR professional body in Singapore authorized to implement the national HR credentials, which is known as the IHRP Certification. Through the IHRP Certification, IHRP aims to enhance the competencies of HR professionals, as well as create developmental and professional pathways for them, allowing HR professionals to be key enablers in their organizations. IHRP is also the appointed program manager for the national Human Capital Diagnostics Tool (HCDT), National HR Awards, such as the SkillsFuture Study Awards for HR and HR Book Prize. Through the HCDT, Study and HR Awards and other Human Capital Initiatives, IHRP supports multiple government agencies reaching out to help organizations in Singapore adopt progressive human capital practices. More information is available at our website at www.ihrp.sg (the “Website”).
1.2 We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the Personal Data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data.
2. COLLECTION OF PERSONAL DATA
2.1 IHRP collects information about you when, you use or access our Website, mobile application/digital platform (“IHRP Connect”), other online products and services, throughout other interactions you have with us and through or in the course of services we may provide to you. Some of the services we provide require us to know who you are. Without limiting the generality of the foregoing, some instances of when your Personal Data may be collected by us include but are not limited to :
(a) when you subscribe or register with us for an account through our Website and/or IHRP Connect;
(b) when you interact with us on our digital platforms;
(c) when you attend IHRP events;
(d) when you register or are nominated for IHRP Certification;
(e) when information is obtained from your employer as part of IHRP’s outreach and certification programme;
(f) when information is provided to us by various government agencies for the purpose of discharging our obligations under the respective Letter of Agreements (LOA)
2.2 Personal Data collected by us about you may include but is not limited to the following:
(a) contact data, name, NRIC or FIN, passport or other identification number, photograph or image of yourself, telephone number(s), mailing address(es), email address(es), educational institutions attended, occupation, and any other information you provide to us, whether in any forms you may have submitted to us, through your interaction with IHRP and its agents/employees, through your opening an account with IHRP or other means;
(b) other information that you voluntarily choose to provide to us (such as information shared by you with us through emails, or through online or digital platform(s) and activities);
(c) information about you that we receive from third parties (such as your employer) or collect from publicly available sources, provided always that we will only do so in compliance with the PDPA;
(d) photographs and video footage identifying you; and
(e) your use of the Website and/or our services, including cookies, IP address, policy and usage history information.
2.3 You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to provide you with certain products and services, or transact with you, that depend on the collection, use or disclosure of your Personal Data.
2.4 We may also collect and store certain information automatically when you visit the Website. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Website (including date and time), cookie number and your activity on the Website, including the pages you visited, the searches you made and, if relevant, the services you purchased. Depending on the circumstances at hand, one or more of the aforesaid in this sub-paragraph may or may not constitute Personal Data.
2.5 We may receive information about you from third parties such as if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on the Website with your profile on those other websites or social media platforms.
3. COOKIES AND TECHNOLOGY
3.1 Various technologies may be used on our Website, digital platforms or our emailing system in order to make it more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s Personal Data. In all cases where your Personal Data is collected, we will abide by the requirements of the PDPA. These technologies include but are not limited to cookies, web beacons, tracing links, click stream data and web analytics.
3.3 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.
3.4 You can block or deactivate cookies in your browser settings.
3.5 We use log-in cookies in order to remember you when you have logged in for a seamless experience. We use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information.
3.6 IHRP may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. Depending on circumstances, the IP address could be considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). IHRP collects your IP address in order to facilitate its administration and improvement of the Website. The information derived from your IP address can help IHRP diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Website.
3.7 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, using IHRP’s online payment services.
(b) Analytical/performance cookies. They allow IHRP to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps IHRP to improve the way the Website works, for example, by ensuring that users are able to use custom features.
(c) Functionality cookies. These are used to recognize you when you return to our Website. This enables IHRP to personalize its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. IHRP will use this information to make the Website and the advertisements more relevant to your interests. IHRP may also share this information with third parties for this purpose.
3.9 Our Website uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Website and ways that we can improve your experience.
3.11 For further information on types of cookies and how they work visit www.allaboutcookies.org
4. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF YOUR PERSONAL DATA
4.1 IHRP will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes:
(a) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Website and/or IHRP Connect, including identifying you for login to the Website and/or IHRP Connect, our portals and identifying you for other online services provided by or on behalf of us. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Website and/or IHRP Connect, using your login credentials of a Social Networking Site; or
(ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Website and/or IHRP Connect,
it may result in information or your Personal Data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your Personal Data;
(b) monitoring, processing and/or tracking your use of the Website and/or IHRP Connect in order to provide you with a seamless experience, facilitating or administering your use of the Website and/or IHRP Connect, and/or to assist us in improving your experience in using the Website and/or IHRP Connect;
(c) dealing with, assessing and/or processing your request or application for our certification(s) and/or the purchase of and/or subscription to our products and/or services and/or your application for and participation in our events.
(d) registering and/or managing you as a customer of, member of, account holder of IHRP and/or its certification, or subscriber to IHRP’s products and/or services; and/or to deal with, process and/or administer the account that you may open with us, whether a membership/certification account or otherwise, including to facilitate your transactions or activities on the Website and/or IHRP Connect, or your transactions or activities with us, or your certification that you have applied for or have obtained;
(e) administering, facilitating, managing, processing and/or dealing with your relationship with us, your certifications with us, any transactions or activities carried out by you on the Website or at our office(s) or business premise(s). This includes processing your application, transactions and/or payment; implementing transactions and the supply of products, certification and/or services to you that you have requested; sending you reminders of assessment/certification/re-certification by email, postal mail or other means in accordance with the PDPA; facilitating, administering, processing and/or monitoring your CPD activities and recertification progress;
(f) considering your suitability for, nominating you, administering and/or dealing with your nomination for or participation in : national level taskforce/committees, fellowship, awards and other areas of or schemes for recognition of your achievements, as a coach/mentor of IHRP or to be an IHRP ambassador;
(g) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us;
(h) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Website and/or IHRP Connect, your membership, certification and/or account with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(i) providing services to you as our account holder, as our certification holder, as our customer, as a member of our certification or other program(s) or when requested by you; dealing with or administering your participation in events organized by us;
(j) for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, certifications, services and/or events (including those of third party organizations with which IHRP may collaborate with) that IHRP (including its affiliates/related corporations) or such third party organizations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, certifications, services and/or events exist now or are created in the future:
(ii) if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA; and/or
(iii) Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, IHRP reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if :
(1) there is an ongoing relationship between IHRP and you and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or
(2) the law permits.
For the avoidance of doubt, this subparagraph is without prejudice to subparagraph [(r)] below for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;
(k) for marketing and publicity purpose through the use of your name, certification level and/or photographs, or video images captured by videography, that are taken of you during courses, seminars, events or programmes organized by IHRP or in which IHRP is involved, at which you appear, participate in or attend. Your name, certification level and/or image captured in photographs or videos during the aforementioned activities will/may be collected, used, disclosed, processed and published by or on behalf of us, in our corporate videos, our website(s), materials such as newsletters or other publication created or issued by us, any materials/books recording your participation in such activities, for marketing, publicity, or factual purpose, and you agree to the same. You can at any time give us written notice that you withdraw your consent to this by contacting our Data Protection Officer at firstname.lastname@example.org. For the avoidance of doubt, your withdrawal will bring a stop to subsequent new publication by us of the use of your name, certification level and/or image in such photographs or videos after we receive your withdrawal notice and upon the expiry of a reasonable time to put into effect your withdrawal but logically will not affect publications that have been made prior to your notice to us.
(l) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (whether Singapore or other country) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (whether Singapore or other country) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (whether Singapore or other country) or that may have been put in place by us or our affiliates/associated companies;
(m) for keeping record of your conversation with our staff or agents in dealing with any queries, interactions or conversations you may have with us, for one or more of the Purposes here including for training purpose. If we do so record your conversation, we will inform you about it, whether by a sign or through a message or otherwise, before we commence recording of the conversation. You may choose not to have the conversation recorded by informing the IHRP staff who is interacting with you during the conversation, or if there is no human staff interacting with you such as in a voice recorded message by not continuing with that conversation;
(n) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(o) complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements, of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other country), with which we or our affiliates/associated companies are expected to comply;
(p) complying with or as required by any request or direction of any governmental authority (whether Singapore or other country) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether Singapore or other country). For the avoidance of doubt, this means that we may/will disclose your personal data to such parties upon their request or direction;
(q) conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Website, or improve any of our products, certification or services. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face or phone interview survey, by way of email or postal mail;
(r) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;
(s) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of IHRP or that of its affiliates/related corporations;
(t) record-keeping purposes, to create reports with respect to our transactions with you, and/or producing statistics and research of such transactions for internal and/or statutory reporting and/or record-keeping requirements, of IHRP or of IHRP’s Stakeholders;
(u) maintaining and developing our business systems and infrastructure including testing and upgrading of these systems;
(v) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves IHRP as a participant or involves only a related corporation or affiliated company of IHRP as a participant or involves IHRP and/or any one or more of IHRP’s related corporations or affiliated companies (if any) as participant(s), and there may be other third party organizations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organization or of any of the business or assets of an organization;
(w) anonymization of your personal data. In this regard, you acknowledge that Personal Data that has been anonymized is no longer Personal Data and the requirements of the PDPA would no longer apply to such anonymized data;
(x) IHRP’s or IHRP’s Stakeholders’ reporting purposes including but not limited to reporting on IHRP’s business and/or performance (“IHRP’s Stakeholders” means the Ministry of Manpower (MOM), the National Trades Union Congress (NTUC) and Singapore National Employers Federation (SNEF));
(y) to deal with the or as part of a bankruptcy, winding up, reorganization, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of IHRP; and/or
(z) for internal IHRP training purpose so that IHRP can train its staff and/or agents to improve its products, services, certification and/or customer service.
(aa) To maintain the IHRP on-line Directory of certified professionals for public verification purposes comprised of your name, IHRP certificate number, certification level and validity period only.
(bb) Other purposes which are consistent with IHRP’s objective of promoting high professional standards for the HR profession and facilitating improvement in human capital practices
(the purposes set out above shall be collectively referred to as the “Purposes”).
4.2 IHRP may/will need to disclose your Personal Data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your Personal Data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 4.1, such third parties include :
(a) our stakeholders, namely the Ministry of Manpower (MOM), the National Trades Union Congress (NTUC) and Singapore National Employers Federation (SNEF);
(b) our related corporations and affiliates either in Singapore or overseas
(c) any of our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf or otherwise, including but not limited to those which provide administrative or other services to us such as mailing houses, research companies, call centers, telecommunication companies, logistics companies, information technology companies and data centers;
(d) our business partners;
(e) any actual or proposed assignee or transferee of the business of IHRP, or a merged entity in the event IHRP is merged to create the said merged entity; and
(f) third parties to whom disclosure by IHRP is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.
4.3 IHRP will not sell or rent your Personal Data to any third party.
4.4 For the avoidance of doubt, you acknowledge and consent to IHRP sharing anonymized information such as but not limited to the sharing of anonymized aggregate information about our customers or members or certificate holders with advertisers, marketing partners and other third parties. For the further avoidance of doubt, the PDPA does not apply to anonymized data that does not identify an individual and the PDPA does not provide you with a right to object to an organization handling or processing anonymized data.
4.5 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by emailing us at email@example.com. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your Personal Data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, depending on the extent of your withdrawal, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you or us being unable to maintain your certification or other consequence depending on your withdrawal.
4.6 We may collect, use, disclose or process your Personal Data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the PDPA or by law.
4.7 We may/will also be collecting from sources other than yourself, Personal Data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive). We will only carry out the aforesaid in compliance with the PDPA.
5. PROVISION OF THIRD PARTY PERSONAL DATA BY YOU
5.1 Should you provide IHRP with Personal Data of individual(s) other than yourself, you represent and warrant to IHRP and you hereby confirm that :
(a) prior to disclosing such Personal Data to us, you would have and had obtained consent from the individuals whose Personal Data are being disclosed to us, to:
(i) permit you to disclose the individuals’ Personal Data to IHRP for the Purposes; and
(ii) permit IHRP to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes, as set out in paragraph 4.1 above;
(b) any Personal Data of individuals that you disclose to us is accurate; and
(c) you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to IHRP and for IHRP to collect, use, disclose and process such Personal Data for the Purposes.
6. WEBSITE AND/OR IHRP CONNECT NOT INTENDED FOR MINORS
6.1 We do not and do not intend to, transact through the Website and/or IHRP Connect directly with anyone we know to be under the age of 18. If you are under the age of 18, you should use the Website and/or IHRP Connect only with the involvement of a parent or guardian and should not submit any Personal Data to us. By providing any Personal Data to us, you declare that you are over the age of 18.
6.2 IHRP strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission.
7. PROTECTING AND MANAGING YOUR PERSONAL DATA
7.1 We will endeavor to take all reasonable steps to ensure your Personal Data is kept confidential and secure, and to take appropriate technical and organizational measures to prevent unlawful or accidental destruction, accidental loss, unauthorized disclosure or access or other unlawful forms of processing. We will not rent, trade, distribute or sell any Personal Data that you give us to any third party unless we receive your prior consent or applicable law permits the same.
7.2 We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
7.3 We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organization. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on your account page or by contacting us through firstname.lastname@example.org.
7.4 We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
8.1 You have the right to ask us not to use your Personal Data for marketing purposes. Please let us know if you want to withdraw your consent by emailing us at email@example.com.
8.2 You have the right to access and/or correct any Personal Data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at firstname.lastname@example.org. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We may charge you a reasonable fee for the handling and processing of your requests to access your Personal Data. If so, we will provide you with a written estimate of the fee. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
8.3 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of Personal Data from being subject to your access request.
8.4 For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will correct your Personal Data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request. We will send the corrected personal data to every other organization to which the Personal Data was disclosed by us 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.
8.5 We hold and deal with your Personal Data in accordance with the PDPA.
9. COMPLAINT PROCESS
9.1 If you have any complaint or grievance regarding about how we are handling your Personal Data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
9.2 Please contact us with your complaint or grievance by emailing us at email@example.com.
9.3 Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “PDPA Complaint”.
9.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
10.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organization such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the law shall continue to apply.