BCS Singapore - Secure & Efficient Electronic Payment Systems

DATA PROTECTION POLICY

The purpose of this Data Protection Policy is to set out how Banking Computer Services Private Limited (“BCS”) manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).

This policy applies to BCS and outlines our practices in handling of Personal Data we collect and hold about our customers, vendors, suppliers, partners, and all others who come into contact with us across all touch points of our business operations, including those seeking employment with us.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to BCS, as well as its representatives and/or agents (“Representatives”) (BCS and Representatives collectively referred to herein as "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Person Data to the Companies’ authorized service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to BCS in respect of your Personal Data, and your consents herein are additional to any rights which BCS may have at law to collect, use or disclose your Personal Data.

BCS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

  1. PERSONAL DATA

    In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

    Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

  2. COLLECTION OF PERSONAL DATA

    1. Generally, we collect Personal Data in the following ways:

      1. when you submit any form relating to our services;

      2. when you interact with our staff, including helpdesk support staff and other representatives, for example, via telephone calls, letters, face-to-face meetings and email;

      3. when you request that we contact you, be included in an email or other mailing list;

      4. when we seek information from third parties about you and/or receive your Personal Data in connection with your relationship with us, including for job applications;

      5. when you submit your Personal Data to us for any other reason.

    2. When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information.

    3. If you provide us with any Personal Data relating to a third party (e.g. information on your customers, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.

    4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

  3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

    1. Generally, BCS collects, uses and discloses your Personal Data for the following purposes:

      1. responding to your queries and requests;

      2. verifying your identity;

      3. managing the administrative and business operations of BCS and complying with internal policies and procedures;

      4. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

      5. matching any Personal Data held which relates to you for any of the purposes listed herein;

      6. preventing, detecting and investigating crime, including fraud, and analysing and managing commercial risks;

      7. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

      8. legal purposes (including but not limited to obtaining legal advice, dispute resolution and enforcing our legal rights and obligations);

      9. managing and preparing reports on incidents and accidents;

      10. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and

      11. any other purpose relating to any of the above.

    2. In addition, BCS collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

      1. If you are an employee, officer or owner of an external service provider, vendor, consultant or contractor engaged by BCS:

        1. managing project tenders or the supply of goods and services;

        2. processing and payment of invoices;

        3. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or

        4. any other purpose relating to any of the above.

      2. If you submit an application to us as a candidate for an employment or representative position:

        1. conducting interviews;

        2. processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;

        3. providing or obtaining employee references and for background screening;

        4. assessing your suitability for the position applied for;

        5. processing staff referrals; and/or

        6. any other purposes relating to any of the above.

      3. If you are an existing employee of BCS:

        1. providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring awards;

        2. staff orientation and entry processing;

        3. administrative and support processes relating to your employment, including its management and termination, as well as staff benefits, including travel, manpower, business continuity and logistics management or support, processing expense claims, medical insurance applications, leave administration, training, learning and talent development, and planning organising corporate events;

        4. providing you with tools and/or facilities to enable or facilitate the performance of your duties;

        5. compiling and publishing internal directories and emergency contact lists for business continuity;

        6. managing corporate social responsibility projects;

        7. conducting analytics and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;

        8. ensuring that the administrative and business operations of BCS function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within BCS, your work emails and personal digital and storage devices); and

        9. any other purposes relating to any of the above.

      4. If you sit on the BCS Board of Directors:

        1. facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);

        2. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);

        3. administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee);

        4. managing insurance programmes through OCBC Group or otherwise; and/or

        5. any other purpose relating to any of the above.

    3. In your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

  4. DISCLOSURE OF PERSONAL DATA

    BCS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

    1. companies providing services relating to insurance and/or reinsurance directly or indirectly to BCS;

    2. agents, contractors or third party service providers who provide operational services to BCS, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to BCS;

    3. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;

    4. our professional advisers such as our auditors and lawyers;

    5. relevant government regulators, government ministries, statutory boards or authorities, and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Insolvency and Public Trustee Office, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;

    6. hotels, travel agents and foreign embassies in relation to overseas travel arrangements for staff;

    7. commercial shops and retailers in relation to providing staff welfare benefits; and/or

    8. any other party to whom you authorise us to disclose your Personal Data to.

  5. USE OF COOKIES

    1. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

    2. Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. Such cookies, if used, are placed by our server and are readable only by us. These cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

    3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

  6. DATA SECURITY

    BCS will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

  7. THIRD-PARTY SITES

    Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. These third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

  8. CONTACTING US – FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

    1. If you:

      1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;

      2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

      3. would like to obtain access and make corrections to your Personal Data records,

      You can approach us via the following channels:

      Email us at DataProtection@bcs.sg
      Call our hotline at 6416 9000

    2. You may also write to our Data Protection Officer as follows:

      Data Protection Officer
      31 Tampines Avenue 4
      OCBC Tampines Centre Two
      #05-01 Singapore 529680

    3. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to BCS on your behalf.

    4. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, BCS may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place. Any withdrawal of consent may also result in the termination of any agreements you have with BCS and you being in breach of your contractual obligations or undertakings. BCS’ legal rights and remedies in such event are expressly reserved.

  9. GOVERNING LAW

    This Data Protection Policy shall be governed in all respects by the laws of Singapore.

Banking Computer Services Pte Ltd

11 Tampines Concourse #02-05 Singapore 528729

T +65 6416 9000
F +65 6785 1057
E info@bcs.sg