We collect, use and store different types of personal information about you, which we have grouped together as follows:

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate interests, we explain what these legitimate interests are.

We may collect personal information about you from the following sources:

• Directly from you
• Cookies – see our cookie statement which can be accessed from our website

Analytics providers, such as Google Analytics

We may share your personal information with the following third parties:

• Our agents and service providers who help us with marketing.
• Event organisers (if we are organising an external event which you are attending)
• The police and other law enforcement agencies
• Relevant regulators, including the Personal Data Protection Commission of the Republic of Singapore in the event of a personal data breach
• Other companies owned or jointly owned by Global University Systems
• Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

Personal data will be kept until there is no longer a legal basis for holding it, and in line with our Retention Schedule or until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.

Where we use your personal information for marketing purposes, we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing, we will add your details to a suppression list which ensures that we remember not to contact you again.

For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

The purposes for which we process your personal data and the legal basis

When you are an applicant, we process your personal data for the purposes of assessing your eligibility to be offered a place in one of our academic or professional programmes.

If you take up a place at LSBF in Singapore, we process your personal data for the purposes of providing our academic or professional programmes and related services. 

If you are unsuccessful or do not take up a place at LSBF in Singapore, we will retain your personal data in line with our retention schedules for statistical and audit purposes or in the event of a complaint or an appeal.

We only process data for specified purposes and if it is justified in accordance with data protection law. The table below lists the various purposes for which we process personal data and the corresponding justification for it. Some processing of your personal data is justified based on contractual necessity. In general, this applies to personal data you provide to us to process your application and if enrolled, to monitor academic performance. Without that information, we would be unable to provide you with your chosen academic programme and related support services.  Some personal data is also required to fulfil our legal obligations regarding immigration. A failure to provide that information would prejudice your student visa application.

Where the basis of processing your personal data is contractual necessity and you fail to provide the personal data in question, LSBF in Singapore may not be able to process your application or provide you with the programme for which you have applied.  A failure to provide immigration-related data may result in failure to obtain a study visa for those students who require it.

There may be additional purposes for processing your data in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. These additional processes are carried out in accordance with our policies, and we are committed to informing you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.

We understand the importance of transparency and privacy, and we strive to ensure that you are fully informed about how your data is being used. If you have any questions or concerns about the processing of your personal data, please do not hesitate to reach out to us. We are here to assist you and address any inquiries you may have.

On occasion we may need to share your data with third parties. The following table lists what information we may share with whom.

* This will only be shared on request and where there is a legal basis for doing so.

The retention period for your personal data is set out in the Student Records Retention Schedule, please contact our DPO for more information.

As a data subject, you have the following rights in relation to your personal data processed by us:

• To gain access to your personal data;
• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
• To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
• To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month.

For more information on your rights, if you wish to exercise any of the above rights or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer.

LSBF in Singapore maintains a data protection registration with the Personal Data Protection Commission of the Republic of Singapore “PDPC”, the independent authority which oversees compliance with the Data Protection Legislation. LSBF in Singapore registration number is 201008079C.  Please visit the PDPC’s website for details.

You have a right to complain to the PDPC about the way in which we process your personal data. You can make a complaint on the PDPC website https://www.pdpc.gov.sg/

However, if you feel that your concerns have not been adequately addressed and you are considering escalating the issue to the Personal Data Protection Commission, we kindly request that you contact us initially. We are committed to resolving privacy-related issues promptly and transparently, and we value the opportunity to address any concerns directly with you. Please feel free to reach out to us, and we will do our utmost to assist you.

London School of Business and Finance (LSBF Singapore Campus)

LSBF in Singapore processes personal data for the purposes of arranging graduation ceremonies, conferring awards on graduates and documenting the event for the purposes of celebrating graduate achievements and for the future promotion of LSBF in Singapore.

Article 6(1) of the General Data Protection Regulation refers:

Article 6(1) (a) consent, is the basis for including names in the press.

Art 6(1) (f), legitimate interests, is the basis for processing personal data for the purposes of photography and filming where this is for future promotion of LSBF in Singapore. Please see the photography statement provided for further information. It is in the legitimate interests of the controller to use images of successful graduates and ceremonies for future promotion of LSBF in Singapore. To balance the individual’s interests, rights and freedoms LSBF in Singapore provides a fact sheet of all photography and filming activities to individuals prior to the event which details how they can avoid inclusion in the photography and filming and exercise their rights in the event that they are included. It is in the interests of both LSBF in Singapore and individual graduates involved to document these auspicious occasions which are important life events to be celebrated.

Students, LSBF in Singapore employees and all other ceremony attendees, including those invited by students/graduates.

Name, identifcation numbers, contact details, educational details, photographs and moving images.

LSBF Singapore campus’s data management system for the event organisation and images by camera on the day of the event.

Publicly – the publication of names in graduation brochures, photographs online and in any of the LSBF in Singapore’s promotional materials, in printed or electronic format.

Information/photographs are kept securely on LSBF in Singapore’s processing equipment in line with LSBF in Singapore’s information security and data protection policies.

Students are required to keep their information up to date during the course of their studies to ensure that the personal data used at the time of graduation ceremonies is accurate, as this will be recorded at this point as a record of the event.

Please see LSBF in Singapore’s Records Retention Schedules.

No

Ceremony live video streams are broadcast over the internet and may be accessed outside Singapore

Individual photographs and graduation brochures may be transferred outside Singapore by third party individuals.

Attendance at a Graduation Ceremony is optional and students can choose to graduate in-absentia (without attending). This selection is made at the time of registering a student’s intent to graduate.

Graduates can request that they are not photographed/captured on video while crossing the stage during the ceremony.

This request must be made in writing to our DPO and submitted no later than 5 weeks prior the date of the ceremony.

Graduates can request that their name does not appear on the official Graduation Brochure.

This request must be made in writing to our DPO and submitted no later than 5 weeks prior the date of the ceremony.

Enquiries relating to data protection should be made to the LSBF in Singapore’s Data Protection Officer, DPO.

https://www.lsbf.edu.sg/

This privacy notice covers LSBF in Singapore alumni who have completed a course of over 12 months’ duration. It also covers individuals who have chosen to support LSBF in Singapore in some way that is under the remit of the Alumni and Development Department and have consented to be contacted for one of the purposes set out below. This notice only covers processing of personal data for Alumni and Development purposes as set out below. For other personal data processing related to former-students and alumni see the Student Privacy Notice.

We may hold a range of personal data about you from several sources.
The majority of the personal data that we hold is information provided to us by you. If you are an alumna/ alumnus of LSBF in Singapore, personal data collected during your time as a student is transferred from your student record such as your name, date of birth and gender to LSBF in Singapore’s alumni database when you complete a course of over 12 months’ duration. We may also add information provided by you during interactions with you. If you are a supporter of LSBF in Singapore, the personal data we hold may be information provided by you during your interaction with us.
Examples of categories of personal data which we may hold are:

• Personal identifiers – e.g. your name, gender, student/ alumni numbers and your date of birth;
• Contact details – e.g. your postal/ email address, telephone number and contact preferences;
• Information about your time at LSBF in Singapore – e.g. the courses you completed and your membership of clubs and societies;
  Career details – e.g. job role;
• Records of donations – including financial details and Gift Aid status, where applicable
• Communications between the Alumni and Development Department and you;
• Information about your interactions with LSBF in Singapore – e.g. records relating to volunteering activities on behalf of the College, online interactions with us on social media, information about your use of College resources or facilities (e.g. the library), information on your engagement with College meetings, events, groups or networks;
• Results of automated decision making and profiling processes to focus our interactions with you

We may also hold information collected from publicly available sources, such as social network posts, internet searches and websites, and may augment this information with the personal data you provide to us.

We only process data for specified purposes and if it is justified in accordance with data-protection law. In general terms, we process your personal data for the purposes of increasing alumni involvement with the student experience at LSBF in Singapore, fundraising, alumni/ supporter communications and related activities by the Alumni and Development Department. More specifically, these activities may include:

• sending you publications (e.g. alumni magazines and email newsletters about LSBF in Singapore and fundraising activities);
• inviting you to alumni and supporter events, reunions and University events;
• informing you of benefits available to alumni and supporters;
• asking you to support LSBF in Singapore (e.g. contributing to student mentoring schemes or donations);
• fundraising programmes;
• wealth analysis and research in order to improve our understanding of our alumni and supporters, inform our fundraising strategy and target our communications; and
• internal record-keeping and administration (e.g. to process a donation or administer an event which you are attending).

There may be other processing in addition to the above, for example, when you access our website which uses cookies or when we take photos of our events and publish them. This is done on the basis of our policies and we will inform you about such processing at the time when the data is obtained or as soon as reasonably possible thereafter.

Automated individual decision-making means making a decision solely by automated means without any human involvement and profiling means the automated processing of personal data to evaluate certain things about an individual. We may use automated or manual analyses including segmentation or profiling to link data together to send you communication that are relevant and timely, to identify opportunities which may be of interest to you, to help us identify your potential for supporting LSBF in Singapore and to avoid approaching you with opportunities which are not of interest. We may carry out wealth screening to focus our conversations with you and ensure we provide you with an experience which is appropriate for you.

Depending on the activity being carried out, we will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your data, as explained below.

• GDPR Article 6(1) (a) – Consent of the data subject
  Unless mentioned below, we will only process your personal data in relation to alumni and development purposes where we have your consent. This means we will only email you, or call TPS registered numbers, if we have your express consent to do so. We may contact you by post unless you have asked us not to. We will also only contact you about College news, events or to ask for a donation if we have your express consent to do so.
• GDPR Article6 (1)(c) – Processing is necessary for compliance with a legal obligation
  If you make or have made a charitable donation we will process your name, address, and donation information under 6(1)(c) of the GDPR for the purpose of administering your donation and claiming Gift Aid on your behalf. We may also use available sources to carry out due diligence checks to meet money laundering regulations. If you withdraw consent, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. The College has a legal obligation to supply some of the information we hold about you, as a graduate, to the Council for Private Education the official agency for the collection, analysis and dissemination of quantitative information about higher education in Singapore.
• GDPR Article 6.1(f) -Processing is necessary for the pursuit of our legitimate interests.
  Processing of student record data for alumni under legitimate interests for the purpose of monitoring our academic services and providing you with information (e.g. copy of transcript, confirmation of degree etc.) is covered in the Student Privacy Notice.

Your personal data is held securely on LSBF in Singapore’s alumni and supporter database, which is accessible by a limited number of staff and is secured. Any transfer of your personal data outside Singapore will be subject to stringent controls and mechanisms to offer adequate protection. Further information about Privacy Shield can be found at Data Privacy Framework
We ensure we have appropriate data sharing agreements in place before sharing your personal data.
We do not sell your personal data to third parties under any circumstances, or permit third parties to sell the data we have shared with them.
We understand the importance of transparency and privacy, and we strive to ensure that you are fully informed about how your data is being used and protected.

As a data subject, you have the following rights in relation to your personal data processed by us:

• to gain access to your personal data;
• to rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
• to have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
• to object to the processing of your personal data for marketing purposes;
• to object to the processing of your personal data when such processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing;
• to restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period; and
• to ask for the transfer of your data electronically to a third party.

Personal data in support of your alumni relationship with LSBF in Singapore will be kept until there is no longer a legal basis for holding it, until you object to the processing of your data (e.g. for direct marketing purposes) or until you withdraw your consent.
If you ask us to delete your personal data, we will continue to maintain a core set of personal data comprising very brief information to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.

You can update, amend or correct the data we hold about you by contacting the Alumni and Development Department by email, phone or post. You can also change your communication preferences at any time to restrict how we process your data, or opt out of some or all communication. We will also review your consent and preferences at least every two years.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer, DPO

LSBF in Singapore maintains a data protection registration with the Personal Data Protection Commission of the Republic of Singapore “PDPC”, the independent authority which oversees compliance with the Data Protection Legislation. LSBF in Singapore registration number is 201008079C.  Please visit the PDPC’s website for details.

You have a right to complain to the PDPC about the way in which we process your personal data. You can make a complaint on the PDPC website https://www.pdpc.gov.sg/

However, if you feel that your concerns have not been adequately addressed and you are considering escalating the issue to the Personal Data Protection Commission, we kindly request that you contact us initially. We are committed to resolving privacy-related issues promptly and transparently, and we value the opportunity to address any concerns directly with you. Please feel free to reach out to us, and we will do our utmost to assist you.

What is Personal Data?

'Personal data' means any information which identifies you as an individual. It may include your name but it may also be other information such as your date of birth, nationality and gender which when combined identify you.

This Statement and LSBF in Singapore data protection obligations

In accordance with the General Data Protection Regulation (the “GDPR”),  the Data Protection Act 2018 (the “DPA”) and  the Personal Data Protection Act of 2012 (No. 26 of 2012), together, the “Data Protection Laws”, we are a Data Controller as we determine the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This means that we are legally responsible for the personal data we collect and hold about you. It also means that we must comply with the data protection principles (see below). One of our responsibilities is to tell you about the different ways in which we use your personal data – what information we collect (and our legal basis for doing so), why we collect it, where we collect it from and whether (and with whom) we will share it. We also need to tell you about your rights in relation to the information. This notice provides further details about all the above.

In order to comply with our contractual, statutory, and management obligations and responsibilities, we need to process personal data relating to our employees, including ‘sensitive’ or special categories’ of personal data, as defined in the Data Protection Laws which includes information relating to health, racial or ethnic origin, and criminal convictions.

All personal data will be processed in accordance with the Data Protection Laws and London School of Business & Finance, Singapore Campus - Privacy Policy: https://www.lsbf.edu.sg/privacy-policy/

 Using your information in accordance with Data Protection Laws

Data Protection Laws require that we meet certain conditions before we are allowed to use your data in the manner described in this notice, including having a 'legal basis' for the processing.

The legal basis on which your personal data are collected, the types of personal data, and the purposes for which they are processed is given below.

Application for employment (Subsection)

We need to process your personal data that you supplied to London School of Business & Finance, Singapore campus, as part of your application for a career opportunity with us. This is to ensure that your application can be considered by the relevant department. In your application we will collect the following information:

Personal data gathered

In your application we will collect the following information

First Name(s)
Last Name
Title
Telephone (Mobile)
Your personal Email
Details of your Secondary and/or Tertiary education
Professional qualifications
Statement in support of your application
Details within your submitted Curriculum Vitae (CV)

Information about your present and employment history for the previous five (5) years including:
Name of Employer(s)
Address Line 1
Address Line 2
Town
County
Postcode
Job Title
Date From
Date To
Notice Required

In addition, we may contact your referees as provided in your application to confirm the employment information that you provided. 

Special categories personal data

As part of your employment you will be asked to provide equality and diversity information, this may include data concerning:
 

Any disability
Your ethnicity
Your sexual orientation
Your religious beliefs

You have the right to not provide this information, in which case London School of Business & Finance, Singapore campus will inform statutory bodies that you elected not to provide this information

Criminal records information

In some circumstances we may process your information to undertake a Background  check, as required by law.

During your employment

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, data concerning sex life or sexual orientation. We will process this data, as well as the data provided in your application in order to perform our obligations arising from your contract of employment with us. The additional personal data we process to meet these responsibilities includes:

Additional data-personal information

The additional personal data (including some special category personal data) we process to meet our responsibilities as an employer includes the following:

Previous sickness information including the reasons for the absence
Bank account details
Passport details
Visa details
Medical Claims
Leave entitlement
CPF data
Remuneration and benefits
Emergency contacts
Trade Union Membership

Statutory responsibilities

We may process your personal data in order to meet responsibilities imposed on us by legislation. The personal data processed to meet statutory responsibilities includes, but is not limited to, data relating to:
tax;
national insurance;
statutory sick pay;
statutory maternity pay;
family leave;
work permits, and
equal opportunities monitoring.

Our lawful basis for processing

The lawful basis for processing personal data will be:

Article 6(1) (b) Contract 

Article 6(1) (c) Legal obligation 
Article 6(1) (f) Legitimate interest

Purpose of processing

We will use your personal data in connection with your employment relationship with us, including for the following purposes:

To facilitate staff training, such as e-learning.
Managing our accounts and records and providing commercial activities to our clients.
For the use of CCTV systems to monitor and collect visual images for the purposes of security and the prevention and detection of crime.

To provide you access to relevant systems to undertake your role.
To fulfil our obligations for the contract of employment.
Processing recruitment applications.
Talent, performance and succession planning.
Paying and reviewing salary and other remuneration and benefits.
Providing and administering benefits.
Undertaking performance appraisals and reviews.
Policy and Legal Governance requirements and compliance.
Internal audit and data collection.
Legal compliance, requirements and obligations.
Maintaining sickness and other absence records.
Providing references and information to future employers and, if necessary, governmental bodies.
Processing information regarding equality of opportunity and treatment of data subjects in line with the monitoring of equal opportunities and access.
The information we process may be held on LSBF in Singapore’s Corporate systems some of which may be owned and operated by third parties. Where we engage with such third parties, we insist upon strict contractual requirements to be adhered by them to protect the personal data. 

Special categories personal data

The Data Protection Laws define ‘sensitive personal data’ or 'special categories of personal data' as information about racial or ethnic origin; political opinions; religious beliefs or other similar beliefs; trade union membership; physical or mental health; sexual life. In certain limited circumstances, the Data Protection Laws permit us to process such data without requiring the explicit consent of the employee.

 (a)     We will process sensitive personal data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and consent.
(b)   Other than in exceptional circumstances, London School of Business & Finance, Singapore campus will process sensitive personal data about an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding our equal opportunities policies and related provisions.
(c)   Information about an employee’s criminal convictions will be held as necessary and only in accordance with Data Protection Legislation.

The lawful basis for processing this special category personal data will be:
The GDPR Article 9(2)(b) ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.

Sharing personal data

We sometimes need to share the personal information we process, with you and with other organisations. Where this is necessary, we are required to comply with all aspects of the Data Protection Laws.

We may use third party providers to deliver our services, such as externally hosted software or cloud providers, and those providers may involve transfer of personal data outside Singapore. Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with Singapore data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

Where necessary or required we will share your information with:

• family, associates and representatives of the person whose personal data we are processing;
• current, past or prospective employers;
• healthcare, social and welfare organisations;
• suppliers and service providers;
• financial organisations;
• auditors;
• police forces, security organisations;
• courts and tribunals;
• prison and probation services;
• legal representatives;
• local and central government;
• consultants and professional advisers;
• trade union and staff associations;
• survey and research organisations, and
• press and the media.

Furthermore, in order to fulfil its statutory responsibilities, London School of Business & Finance, Singapore campus, is required to provide some of employee’s personal data to government departments or agencies e.g. provision of salary and tax data to Revenue & Customs.

Automated processing

London School of Business & Finance, Singapore does not use automated processing and decision making without manual intervention.

Principles

We will handle your personal data in accordance with the principles set out below:

Keeping personal data up-to date

The Data Protection Laws require us to take reasonable steps to ensure that any personal data we process is accurate and up to date. Employees are responsible for informing us of any changes to the personal data that they have supplied during the course of their employment. You can contact hr@lsbf.edu.sg to update your personal data.

Retention of your data

London School of Business & Finance, Singapore campus, retains personal information it collects from you where there is an ongoing business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When there is no ongoing business need to process your personal information, London School of Business & Finance, Singapore campus, will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then London School of Business & Finance, Singapore campus, will securely store your personal information and isolate it from any further processing until deletion is possible. Personnel files are retained for a period of at least 6 years from the date of termination of employment.

How does London School of Business & Finance, Singapore campus, protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Your rights

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you.  This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you.  This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims. 

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a compliant, please contact our Data Protection Officer.

Changes to our privacy Policy

Any changes we make to this privacy notice in the future will be [posted on this page] and, where appropriate, notified to you by e-mail.

Who regulates the use of my personal information?

London School of Business & Finance, Singapore campus, maintains a data protection registration with the PDPC, the independent authority which oversees compliance with the Data Protection Legislation. London School of Business & Finance, Singapore registration number is 201008079C and sets out, in very general terms, the full range of purposes for which we use, staff and all other personal information. Please visit the PDPC website for details.

Who do I contact with questions?

The data controller for the purposes of the General Data Protection Regulation is London School of Business & Finance, Singapore campus. For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer, DPO.

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the Personal Data Protection Commission of the Republic of Singapore. Full details may be accessed on https://www.pdpc.gov.sg/

This notice applies to individuals applying to work with us, including prospective directors, employees, trainees, apprentices, work experience students, workers, consultants and contractors. It applies whether the work applied for is part time or full time; or permanent, temporary or for a fixed term.

We are a data 'controller', which means we are responsible for deciding how we hold and use your personal information.

This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information. We may amend this notice at any time.

In this privacy notice, 'your personal information' means your personal data i.e. information about you from which you can be identified. Sections 5 and 6 below set out your personal information that we may process.

Your 'personal information' does not include data where the identity has been removed (anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process. 

'Special categories of personal information' means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 5 below, and data described at section 6, falls within these 'special categories' or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out at sections 5 and 6 below. 

Your personal information will come from you or us, and may also come from the following sources:

• Recruitment agencies and apprenticeship providers may provide us with the following personal information: personal contact details, qualifications, schools attended, details of previous employment(s), skills and experience, hobbies and interests, and interview notes.
• Credit reference agencies may provide us with the following personal information: personal contact details, date of birth, details of credit accounts and usage and an overall credit score.
• Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: role(s) held, dates of employment, details of skills and capabilities and any other information that helps to assess your suitability for the position applied for.
• London School of Business & Finance, Singapore campus, staff may provide us with: personal information about you if they are referring you for recruitment.
• Medical professionals may provide us with the following personal information: information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made to the recruitment process because of that disability.
• Professional bodies such as the Association of Chartered Certified Accountants, may provide us with the following personal information: qualifications, registrations, practising certificates, accreditation details and membership details.
• Google and social networking accounts (such as LinkedIn): as part of the recruitment process, we may source personal information relating to roles you have held, details of skills and capabilities and any other information that helps us to assess your suitability for the position applied for.

Some of the sources above will only be relevant in certain circumstances, or if you have applied for a particular role. If you would like more information on the source of your personal information, please contact the HR department.

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out in the following table, and also to:

• Retain records relating to the recruitment process;
• Establish, exercise or defend legal claims;
• Comply with the law or requirements of any regulator; and
• Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

To enable us to make recruitment decisions and assess suitability for work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 6.

We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

If you have accepted an offer of work from us that is subject to a Background  check, we will ask you to obtain the check (at the appropriate level) from  the Police  and provide us with a copy of this.

Sections 5 and 6 above identify personal information that we may need to enter a contract with you. You are not obliged to provide this information, but if you don't provide it, we may not be able to proceed with the recruitment process or enter into the contract.

In some circumstances, the provision of your personal information relates to a statutory requirement. This includes:

• Documentation confirming your right to work in Singapore – you are not obliged to provide this information, but if you don't provide it, we will not be able to enter into a contract with you.

We may share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

• Health professionals and occupational health providers involved in your care, in order to consider reasonable adjustments to the recruitment process for disabled applicants.
• Relevant regulators such as CPE, SSG, The Association of Chartered Certified Accountants etc.,
• Our professional advisors.
• Other third parties as necessary to comply with the law. 

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you. 

We share your personal data within the GUS Group. This will involve transferring your data outside Singapore.

Whenever we do this, to ensure that your personal data is treated by those third parties securely and in a way that is consistent with Singapore data protection law, we require such third parties to agree to put in place safeguards, such as the EU model clauses or equivalent measures.

If you don't start work with us following the recruitment process, we will retain your personal information for six months thereafter:

• to allow us to establish, exercise or defend legal claims; and
• for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again.

If you ask us to retain your personal information so that we can contact you to discuss future work opportunities, we will write to you separately, to obtain your explicit consent to retain your personal information for a fixed period of two years on that basis.

If you start work with us following the recruitment process, we will give you a copy of our Staff Privacy Notice, and will retain your personal information as detailed in the Staff Privacy Notice.

As a data subject, you have the following rights in relation to your personal data processed by us:

• To gain access to your personal data;
• To rectify inaccuracies or where appropriate, given the purposes for which your data is processed, the right to have incomplete data completed;
• To have your personal data erased. This is a limited right which applies, among other circumstances, when the data is no longer required, consent has been withdrawn and/or the processing has no legal justification. There are also exceptions to this right, such as when the processing is required by law or in the public interest;
• To object to the processing of your personal data for marketing purposes. You may also object when the processing is based on the public interest or other legitimate interests, unless we have compelling legitimate grounds to continue with the processing.
• To restrict the processing of your personal data. This is a limited right which will apply in specific circumstances and for a limited period.
• To obtain a copy of your data in a commonly used electronic form if the data is processed by automated means and the processing is based on your consent or contractual necessity.
• To not have decisions with legal or similar effects made solely using automated processing, unless certain exceptions apply.

Where we are relying on your consent to process your data, you may withdraw your consent at any time. Your requests will be considered at the latest within one month

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer, DPO.  

If we are unable to adequately address any concerns you may have about the way in which we use your data, you have the right to lodge a formal complaint with the Personal Data Protection Commission of the Republic of Singapore. Full details may be accessed of their website https://www.pdpc.gov.sg/

London School of Business & Finance, Singapore does not collect personal data from former employees after they have left our employment, but it may hold the information that was collected before and during the employment relationship, including:   

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth
• Gender
• Marital status and dependants
• Next of kin and emergency contact information
• NRIC
• Copy of identification (Passport/driving licence)
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension and benefits information
• Start date
• Location of employment or workplace
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Employment records (including job titles, work history, working hours, training records and professional memberships)
• Compensation history
• Performance information
• Disciplinary and grievance information
• CCTV footage and other information obtained through electronic means such as swipe card records
• Information about your use of our information and communications systems
• Photographs

The lawful bases for processing personal data will be:

Article 6(1) (b) Contract 

Article 6(1) (c) Legal obligation 
Article 6(1) (f) Legitimate interest

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the obligations in a contract we have entered into with you, such as the employment contract, or a settlement agreement. Some of the contractual obligations in these contracts continue after your employment has terminated, such as the duty to observe confidentiality.
2. Where we need to comply with a legal obligation.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your vital interests (or someone else’s vital interests). Article 6(d).
2. Where it is needed in the public interest. Article 6(1) (e).

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• Paying you and deducting tax and CPF contributions and other lawful deductions.
• Providing you with any employee related benefits to which you are entitled after the termination of your employment.
• To reimburse you for expenses incurred in the course of your employment.
• Liaising with your pension provider and the trustees/administrators of pension schemes.
• Administering any contract we have entered into with you.
• Business management and planning, including accounting and auditing.
• Gathering evidence for possible grievance or disciplinary hearings.
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
• To prevent and detect fraud.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies (such as the staff survey) to review and better understand employee retention and attrition rates.
• Equality and diversity monitoring
• Publicising our activities (e.g., group photos of events, site visits, etc.).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We may also store and use the following “special categories” of more sensitive personal information that we have collected from you:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Trade union membership.
• Information about your health, including any medical condition, health and sickness records.
• Biometric data.
• Information about criminal convictions and offences.

These “special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for storing and using this type of personal information. Our data protection policy contains details of the safeguards which we are required by law to maintain when processing such data. 

We may process special categories of personal information in the following circumstances:

1. Where we need to carry out our legal obligations or exercise rights in connection with employment.
2. Where it is needed in the public interest: for example, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equality and diversity monitoring and reporting. Where possible, we would seek to anonymise this data.
3. In limited circumstances, with your explicit written consent. However, we do not need your consent to use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may share your data with third parties, including third-party service providers, Government departments and agencies. 

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside Singapore. If we do, you can expect a similar degree of protection in respect of your personal information. 

London School of Business & Finance, Singapore campus will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.

London School of Business & Finance, Singapore campus has a records retention schedule that outlines how long we will retain information.

To determine the appropriate retention period for personal data collected as part of your employment, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee we will retain and securely destroy your personal information after the following periods

• 12 months from date of leaving for employees; except
• Payroll, tax and NIC records which must be retained required for 6 years. This is a legal requirement.

However, these periods only apply to your employment records and not for example to images and materials created and use for marketing and communication purposes (e.g. group photographs taken at away days etc.)

Under certain circumstances, you may have the following rights in relation to your personal data:

Right 1: A right to access personal data held by us about you.

Right 2: A right to require us to rectify any inaccurate personal data held by us about you.

Right 3: A right to require us to erase personal data held by us about you.  This right will only apply where, for example, we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).

Right 4: A right to restrict our processing of personal data held by us about you.  This right will only apply where, for example, you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but we require the data for the purposes of dealing with legal claims. 

Right 5: A right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation.

Right 6: A right to object to our processing of personal data held by us about you.

Right 7: A right to withdraw your consent, where we are relying on it to use your personal data.

Right 8: A right to ask us not to use information about you in a way that allows computers to make decisions about you and ask us to stop.

For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Officer, DPO