1. Introduction
Promises Behavioural Health Centre Pte Ltd (“The Company”) is committed to protecting the personal data of our clients, employees, partners, and all individuals with whom we interact. As a provider of private residential addiction and mental health treatment services, we recognise the sensitive nature of the personal data entrusted to us and strictly adhere to the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”).
This Personal Data Protection Policy (“Policy”) outlines how we collect, use, disclose, and protect personal data through our website and digital services.
2. Definition of Personal Data
Under the PDPA, “Personal Data” refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.
Examples include, but are not limited to:
- Full name, NRIC/passport number, address, phone number, email address
- Medical history, addiction background, family details
- Employment records, educational background, financial information
3. Scope of This Policy
By accessing our website or providing your personal data, you acknowledge that you have read and agree to the terms of this Policy. You represent that you are at least 18 years of age, or have obtained consent from your parent/legal guardian if you are a minor.
4. Collection of Personal Data
We collect personal data through various means, including but not limited to:
- When you complete forms on our website or contact us
- When you engage our services or programmes
- Through correspondence with our staff via email, phone, or in person
- When you apply for employment with us
5. Purpose for Collection, Use, and Disclosure
We will notify you of the purposes for which your personal data is collected, used, or disclosed. These purposes may include:
- Assessing suitability for treatment services or employment
- Processing enquiries, applications or feedback
- Managing and delivering clinical and support services
- Identity verification and appointment booking
- Contact tracing or public health reporting where required
- Compliance with legal and regulatory obligations
- Internal audits, research, service improvement and data analytics
- Communications relating to our services, events or updates
As far as possible, we will not collect more personal data than is reasonably necessary for these purposes.
6. Disclosure of Personal Data
We may disclose your personal data to the following, only to the extent necessary:
- Healthcare providers and allied professionals involved in your care
- Relevant government authorities or regulators
- External IT or administrative service providers
- Legal advisors, insurers, or auditors
- Affiliates or partners involved in programme delivery
7. Consent
In general, we will obtain your consent before collecting, using, or disclosing your personal data.
We may rely on:
- Deemed consent: e.g., where you voluntarily provide information for an intended purpose, where is necessary to perform a contractual transaction with you, or where we inform you of an intended purpose and you do not inform us by a reasonable given time that you do not want us to do so; and
- Exemptions under the PDPA: e.g., in cases of life-threatening emergencies, or if required by law.
You have the right to withdraw your consent at any time (see Clause 9).
8. Marketing and Communication
We may use your contact data to inform you of relevant updates, events, or services. You may opt out at any time by notifying us.
9. Withdrawal of Consent
You may request to withdraw your consent to our use or disclosure of your personal data by contacting our Data Protection Officer (DPO). Please allow up to ten (10) working days for your request to be processed.
Please note: Some personal data may be essential for us to deliver services. Withdrawal may affect our ability to continue providing care or support.
10. Access and Correction Requests
You may request access to or correction of your personal data in our records. Requests should be made in writing to our DPO.
We aim to respond within thirty (30) calendar days. If more time is required, we will inform you accordingly.
11. Accuracy and Updating of Personal Data
We will take reasonable steps to ensure the accuracy and completeness of your personal data. Please update us promptly if your details change.
12. Protection of Personal Data
We implement appropriate physical, technical, and administrative security measures to protect personal data, including:
- Restricted access to records and sensitive information
- Encryption, firewalls, and secure servers
- Confidentiality agreements and staff training
- Access controls based on roles and responsibilities
13. Retention of Personal Data
We retain personal data only as long as necessary for the purposes for which it was collected or to satisfy legal, regulatory or business requirements. When no longer required, data will be securely destroyed, deleted or anonymised.
14. Use of Cookies and Tracking Technologies
Our website may use cookies and similar technologies to enhance user experience and track website traffic. You may disable cookies in your browser settings, but this may affect website functionality.
15. Complaints and Feedback
We take data protection seriously. If you have a concern, complaint or feedback regarding how we handle your personal data, please contact our DPO. We will investigate and respond within fourteen (14) calendar days.
16. Policy Updates
This Policy may be revised from time to time. All changes will be posted on this webpage. Your continued use of our services constitutes your acknowledgment and acceptance of the changes.
17. Contacting Us
If you have questions or requests regarding this Policy or your personal data, you may contact:
Data Protection Officer (DPO)Promises Behavioural Health Centre Pte LtdEmail: dpo@thewinslow.com.sg
