Appropriate Policies and Practices

Data Protection Policies, Stakeholders and Practices

Policies:

According to ABC HORIZON’s Business and Personal Data collected by ABC HORIZON (1.6), the following policies and forms are in place:

1. Data Protection and Privacy Policy for Employees
2. Privacy Policy of Handling of Personal Data in Recruitment
3. Privacy Policy for public, at https://abc-horizon.sg/en/privacy-policy/ 

ABC HORIZON acknowledges the importance of protecting Personal Data and the policies are implemented to manage and protect Personal Data in accordance with PDPA. The policies include: 

• Observance of laws and standards
• Collection, use and/or disclosure of Personal Data
• Consent for collection, use and/or disclosure of Personal Data
• Personal data management and security measures
• Access, correction, and accuracy of Personal Data
• Transfer of Personal Data outside Singapore
• Establishment and continual improvement of Personal data protection management system
• DPO contact information 

Policies and Data Breach Management Process are reviewed annually as a part of PDPA Activities.  If there are significant changes from Amendments to the law, advisory guidelines or change of systems, ad-hoc review will be conducted.  All changes shall be properly documented and endorsed by management.  Updated policies and practices are communicated to employees through internal staff meetings.  As for Data Intermediary and ABC Japan, changes are communicated by DPO as soon as reasonably practical via email.

Stakeholders:

Based on the result of the PDPA Assessment, ABC HORIZON’s Stakeholders are summarized in Appendix Stakeholders.  

• Prior to transferring ABC HORIZON’s Personal Data, ABC HORIZON concludes contractual agreements, check the Privacy Policies and terms and conditions.  
• ABC HORIZON conducts regular reviews to Data Intermediaries by sending the PDPA Questionnaire to confirm how Data Intermediaries are handling ABC HORIZON’s Personal Data.

Practices:

ABC HORIZON conducts internal PDPA Assessment no less than once per annum, to monitor and to identify any gaps. Identified gaps and actions/remediation plans to improve compliance are summarized in the PDPA Assessment Report and ABC HORIZON decides the activities to comply with PDPA (Appendix PDPA Activities). 

Inquiry or Complaint Handling Processes

Responding to inquiries regarding Personal Data

While ABC HORIZON does not collect any Personal Data for business, ABC HORIZON prepares the following three documents in anticipation of Personal Data inquiries from employees and/or job applicants.   

• Personal Data Correction Request Form
• Withdrawal of Collection, Use or Disclosure Form
• Access Request Form

Employees/Job Applicants can always contact inquiries regarding Personal Data addressed to the DPO in writing using the above-mentioned documents. Right of inquiry is stated inside ABC HORIZON’s Employee Handbook. 

Upon receiving inquiries, the DPO shall:

• assess the complexity of inquiries and inform the employee/job applicant who has raised the inquiries, the time needed to investigate and resolve the inquiries; and 
• conduct an investigation regarding the cause of the inquiries. The purpose of the investigation is to establish all of the facts relevant to the issues raised and to provide a full, objective and proportionate response to the employee/job applicant who raised the inquiries. 

Inquiries received will be responded within 3 working days and will investigate and address the issue within 30 working days.  ABC HORIZON proceeds the request in accordance with Personal Data Inquiry Flow and ABC HORIZON requests the individuals to submit the necessary inquiry form depending on the case.  If the inquiries received lead to a data breach incident, the data breach response procedure will be followed.  Inquiry records will be managed by the DPO.

The DPO shall take proper measures to respond to the inquiries based on the investigation results and inform the employee/job applicant if the inquiries have been resolved. 

The DPO shall escalate unresolved inquiries to ABC HORIZON’s management and inform the individual of such situations. 

The DPO shall record the details of all inquiries raised in the Data Protection Incident & Complaint Investigation Form. Such details shall include the inquiry receiving date, name of the individual who raised the inquiry, clear information of the inquiry, actions taken in response to the inquiry and the date when the inquiry was resolved. 

ABC HORIZON takes reasonable steps to protect Personal Data from unauthorized collection, use and/or disclosure. Subject to the provisions of any applicable law or regulations, Personal Data collected by ABC HORIZON may be disclosed to relevant government regulators, statutory boards or authorities, or law enforcement agencies to comply with any laws, rules, guidelines, regulations, or schemes imposed by any governmental authority.  

The DPO takes the lead in responding to all inquiries from employees/job applicants and the DPO communicates with public agencies and decides whether to disclose Personal Data or not, depending on the situation. The DPO also communicates with the Chief Information Security Officer​/Data Protection Officer of ABC Japan in case ABC Japan is involved.

COMPLAINT PROCESS

1. If you have any complaint or grievance regarding 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.
2. Please contact us through one of the following methods with your complaint or grievance :
   1. Singapore telephone number : +65 6291 5457
   2. E-mail : info@abc-horizon.sg
   3. Office address : 152 Beach Road, #18-05, Singapore 189721 Attention it to the ‘Data Protection Officer
3. Where it is an email or a letter through 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 ABC HORIZON to handle. For example, you could insert the subject header as “PDPA Complaint”.
4. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

GENERAL

1. Your consent that is given pursuant to this Policy is additional to and does not supersede any other consents that you provided to ABC HORIZON with regard to processing of your Personal Data.
2. For the avoidance of doubt, in the event that the PDPA 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.

Last Updated on 26th March 2024