Data and Privacy Protection Policy
1.1 Global Resilience Federation Asia Pacific (GRF) and the Operational Technology Information Sharing and Analysis Center (OT-ISAC) (“the Organisations”) take their responsibilities seriously under Singapore’s Personal Data Protection Act 2012 (PDPA) and Europe’s General Data Protection Regulation (GDPR). The Organisations recognize the importance of personal data and seek to properly manage, protect and process it.
This policy outlines which personal data is collected or processed by us, and for what purposes.
1.2 “Personal data” means data about an individual who can be identified from that data, or from that data and other information collected by or accessible by the Organisations. Personal data can include a name, address or date of birth among other information.
1.3 This policy will provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us, that we receive through third parties.
1.4 By providing your personal data to us, you acknowledge that you have read this policy and are consenting to the collection, use, processing and disclosure of your personal data as described in this policy.
1.5 If you provide the personal data of a third party, you agree that the third party has read this policy, and consented to you disclosing their personal data for the collection, use and disclosure by the organisations as described in this policy.
Definition of Data Protection Terms
Data is recorded and stored information.
Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on behalf of the Organisations.
Personal data means any data relating to a living individual who can be identified from that data, such as a name, address, email address. It affects the individual's privacy in some way.
Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
2. Types of Personal Data We Collect
2.1 The Organisations collect information about you when you use the website(s), portal(s)/mobile application(s), forms, surveys, event registrations, event payment processing, and/or other channels and throughout other interactions, communications and services you have with the Organisations.
2.2 Personal data which we may collect include but are not limited to:
(a) your personal information such as your name;
(b) your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;
(c) your past and present employment information such as company name, company type, industry sector, job function and responsibilities, designation, business telephone and fax numbers, business email addresses;
(d) your billing and payment information, including name of the credit/debit cardholder, credit/debit card number, security code and expiry date.
2.3 Other information collected may include messages to the Organisations, professional interest and subscription requests.
2.4 The organisations will collect your personal data in accordance with the PDPA. If you reside in Europe we will collect and process personal data in accordance with the General Data Protection Regulation (GDPR).
2.5 We may collect and store certain information automatically when you visit our website(s) or use our portal(s)/mobile application(s). 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(s) or website/IT portal(s)/mobile application(s) (including date and time), cookie identifier and your activity on our website(s) or website/IT portal(s)/mobile application(s), including the pages you visited, the searches you made and, if relevant, the event passes you purchase.
2.6 We may receive information about you from third parties 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 our website(s) or website/IT portal(s)/mobile application(s) with your profile on those other websites or social media platforms.
3.2 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.
3.3 You can block or deactivate cookies in your browser settings.
3.4 We use log-in cookies to remember you when you have logged in for a seamless experience.
3.5 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.
4. Purposes for which the Personal Data is Collected, Used and Disclosed
4.1 The organisations will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) To consider and/or process your application for more information, to be a member of the Organisations or to sign up for various events that the Organisations host.
(b) To facilitate, process, deal with and/or administer your candidature/membership and/or account with us;
(c) To deal with, process and/or administer your registration for and/or payment of any training courses, events, seminars, workshops, exercises, certification programme, qualification and/or conferences, including to facilitate, administer, process, deal with and/or manage your application for and/or involvement in any events, seminars, information sessions, committees and/or your interest or participation in any events, seminars, information sessions, committees and/or other opportunities that we may make available from time to time;
(d) For the supply of any goods and/or services which we may offer to you or that you may request, obtain or purchase from us;
(e) To deal with, process and/or administer your use of the online services at any of our website(s), portal(s)/mobile application(s) and/or through other digital or telecommunication channels;
(f) For identification and verification purposes in connection with any of the goods and/or services that may be supplied to you by us or that you may request from us;
(g) To carry out your instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) you or on your behalf, including contacting you via phone/voice call, text message and/or fax, email and/or postal mail regarding your instructions, enquiries and/or feedback;
(h) To conduct research, analysis and development activities (including but not limited to data analytics, surveys, focus groups and/or profiling) to improve our services and facilities for your benefit, or to improve any of our programmes or events;
(i) To deal with, process and/or administer your donation(s) or participation/involvement in the provision of the same, or your participation or involvement in any charitable cause, event or project, or in any charity;
(j) To perform, deal with, facilitate and/or administer fund raising activities, and/or to solicit donations from you, and this may entail contacting you and sending you relevant information via various modes of communication including voice/phone calls, emails, SMS and postal mails;
(k) To deal with, process and/or administer contests and lucky draws conducted by us or on our behalf which you have participated in;
(l) To contact you or communicate with you via various modes of communication such as phone/voice call, text message and/or fax message, forms, email and/or postal mail for the purposes of administering, dealing with and/or managing your application for candidature/membership with us, your candidature/membership with us, your account with us, or any other applications (including applications for training courses, events, seminars, workshops, examinations, certification programme, qualification and/or conferences) you make with/through the Organisations. 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;
(m) To process and issue certificates after the completion of the course(s)/certification programme(s)/qualification(s) that you have registered with us;
(n) To carry out due diligence or other screening activities (including security and background checks) in accordance with legal or our risk management procedures that may be required by law or that may have been put in place by us;
(o) 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;
(p) To comply with or as required by any applicable law, 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 elsewhere), with which we or our affiliates/associated companies are expected to comply;
(q) To comply with or as required by any request or direction of any governmental authority; or respond to requests for information from authorities;
(r) For marketing purpose where we send you news, information, materials and/or updates about events, marketing campaigns, products and/or services that we and/or our business partners provide, or on our behalf. In this regard, we will be doing so by way of postal mail and/or electronic transmission to your email address(es). You may unsubscribe from this service in the manner set out in Clause 7 below;
(s) To facilitate and/or deal with payment for goods and/or services provided by us or our subsidiaries, and/or a third party on our behalf including verification of credit card details with third parties and additionally, using the personal data you provide to conduct matching procedures against databases of known fraudulent transactions (maintained by us or third parties);
(t) To deal with, handle and/or conduct security or quality assurance processes, matters and/or arrangements;
(u) To perform internal administrative, operational and technology tasks to facilitate, administer or manage your candidature/membership with us;
(v) To produce statistics and research for internal and/or statutory reporting and/or record-keeping requirements and policy/process reviews;
(w) To disclose to a third party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any jurisdiction, which may be within or outside Singapore;
(x) To help us improve our services to you; and/or
(y) To store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore.
(collectively, referred to as the “Purposes”)
4.2 We may/will need to disclose your personal data to third parties, including to banks, payment service providers and/or other payment gateways, 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 may/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 or more of the above Purposes. Without limiting the generality of the foregoing, such third parties include:
(a) our associated/affiliated organisations;
(b) any of our collaborative partners, agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and
(c) third parties to whom disclosure 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 We may share your information with any member of our group, which means subsidiaries or affiliates, from time to time for one or more of the Purposes.
4.4 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us through www.grfederation.org, www.otisac.org or the sales, communications or member services staff that has contacted you. However, 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 on our website(s) or portal(s)/mobile application(s). Do note that your withdrawal of consent will not affect our ability to collect, use or disclose your personal data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.
4.5 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. For European residents, 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 GDPR.
4.6 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).
5. Storage of Personal Data
5.1 Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on secure servers and any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website(s) or portal(s)/mobile application(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.2 We will 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 (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.
6. Link to other websites
6.1 The Organisations’ website(s), portal(s)/mobile application(s) and other digital and telecommunication channels may contain links to other sites that are operated by third party companies with different privacy practices. You should remain alert and read the privacy statements of other sites. We have no control over personal data that you submit to or receive from these third parties.
7. Withdrawal of Consent for Marketing Purposes
7.1 You have the right to ask us not to use your personal data for marketing purpose. If you no longer wish to receive marketing messages from us, you may request to withdraw your consent by submitting notice to us through contact pages on www.grfederation.org or www.otisac.org or through the sales, communications or members services staff that have been in touch with you.
7.2 The Organisations’ members and participants in courses, seminars, workshop and events may also request to withdraw consent for such marketing purpose by using the links from section 7.1 in the same manner.
8. Data Access and Correction
8.1 You have the right to access and/or correct any personal data that we hold about you, subject to the requirements of the PDPA. European residents will have a right to request access of personal data subject to the requirements of the GDPR. If you would like to request a copy of your personal data being held by us (such right being subject to applicable exemptions), or to update and/or correct the personal data which you have previously provided to us, please write to firstname.lastname@example.org or email@example.com.
8.2 We will need enough information from you in order to ascertain your identity as well as the nature of your request in order to process your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.
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.
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.
8.5 Members and event/workshop/webinar/exercise participants agree and acknowledge that they are responsible for ensuring the accuracy of their personal data.
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 by writing to: firstname.lastname@example.org or email@example.com
9.2 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 the Organisations to handle.
9.3 If you are a European resident and wish to complain about the handling of your personal data, you have a right to raise the complaint with your local supervisory authority in the country where you reside.
10.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. This also applies for European laws for European residents.
The Organisations reserve the right to change this policy with or without notice so please check back frequently.