DATA PROTECTION NOTICE FOR ASSOCIATE TRAINER
DATA PROTECTION NOTICE FOR ASPRI-INSTITUTE OF PROCESS INDUSTRY (ASPRI-IPI)’S ASSOCIATE TRAINERS (CONTRACT FOR SERVICE)
DATA PROTECTION NOTICE FOR ASSOCIATE TRAINERS (CONTRACT FOR SERVICE)
This Data Protection Notice (“Notice”) sets out the basis on which ASPRI‑Institute of Process Industry (“ASPRI‑IPI”) may collect, use, disclose or otherwise process personal data of associate trainers in accordance with the Personal Data Protection Act (“PDPA”). For the purposes of this Notice, references to “we”, “us”, or “our” mean ASPRI‑IPI only, and this Notice does not extend to any other ASPRI entity. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
APPLICATION OF THIS NOTICE
1. This Notice applies to all persons engaged as associate trainers or assessors under a contract for service with ASPRI-IPI (“associate trainers”). All references in this Notice to “engagement” refer to your contract for service with ASPRI‑IPI.
PERSONAL DATA
2. As used in this Notice, “personal data” means data, whether true or not, about an associate trainer 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.
3. Personal data which we may collect in the context of your engagement as an associate trainer with us includes, without limitation, your:
(a) Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
(b) Mailing address, telephone numbers, email address and other contact details;
(c) Employment and training history;
(d) Honorarium information and bank account details;
(e) Details of your next-of-kin, spouse and other family members;
(f) Work-related health issues and disabilities;
(g) Photographs and other audio-visual information; and
(h) Performance assessments and disciplinary records.
4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your engagement or application to be engaged as an associate trainer with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
6. Your personal data will be collected and used by us for the following purposes, and we may disclose your personal data to third parties where necessary, including but not limited to the following purposes:
(a) Performing obligations under or in connection with your contract for service as an associate trainer/assessor with ASPRI‑IPI, including administration of your appointment, allocation of training and assessment assignments, and payment of your training fees and any applicable taxes;
(b) Managing all administrative matters relating to your engagement as an associate trainer, including granting you access to our premises, training facilities and systems as necessary, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) related to your training delivery, and developing policies and procedures for managing associate trainers;
(c) Managing and, where necessary, terminating our engagement relationship with you as an associate trainer, including handling and investigating feedback, incidents, complaints or disputes involving you, and resolving any engagement‑related issues;
(d) Assessing and evaluating your suitability for engagement or continued engagement as an associate trainer with us, including reviewing your qualifications, experience, performance and feedback from trainees or clients;
(e) Ensuring business continuity for our organisation in the event that your engagement with us is, or will be, suspended or terminated, including arranging for replacement trainers and continuity of courses for our clients;
(f) Performing obligations under or in connection with the provision of our training and related services to our clients, including course registration, reporting and funding submissions to relevant agencies and regulators (such as SSG, ITE, MOM and other authorities, where applicable);
(g) Facilitating our compliance with any applicable laws, regulations, codes of practice, guidelines, or requests from public agencies, including responding to regulatory queries, inspections, audits or investigations.
(h) Collecting and processing biometric and/or image data through our CCTV systems upon your entry into our office premises for administrative and work purposes within our organisation, including but not limited to managing and granting access to our premises and investigating any acts, defaults, or suspected misconduct.
7. The purposes listed in the above clauses may continue to apply even in situations where your engagement as an associate trainer with us (pursuant to your contract for service) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
8. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
9. You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in the section ‘Withdrawing your consent‘ below. Please note if you choose not to provide us with the required personal data, or if you withdraw your consent for us to collect, use, and disclose your personal data, we may not be able to:
- Administer your engagement as an associate trainer/assessor, including processing your trainer profile, verifying your qualifications and experience, allocating classes, and communicating course details and changes to you.
- Process payments for your training services (including your training fees, claims and any applicable tax reporting), which may affect our ability to remunerate you for work done.
- Comply with regulatory and funding requirements (for example, submissions to SSG, ITE, MOM and other authorities) that require trainer details; this may affect our ability to assign you to funded or regulated courses.
- Grant you necessary access to our premises, training facilities, IT systems and secure platforms (such as TMS, e‑learning systems or attendance systems) where certain personal identifiers are needed to create and manage your accounts.
- Respond appropriately in emergencies or safety‑related incidents involving you or your classes, due to lack of emergency contact information and, where applicable, health‑related information needed for safety and incident reporting.
- Maintain complete and accurate records for scheduling, performance feedback, quality assurance, audits and internal communications, which may affect our ability to continue your engagement or offer you future training assignments.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
10. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Association of Process Industry (ASPRI‑IPI) or another person. In relying on the legitimate interests exception of the PDPA, Association of Process Industry (ASPRI‑IPI) will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
11. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services;
c. Network analysis to prevent fraud and financial crime, and perform credit analysis; and
d. Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
12. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
13. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
15. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
16. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
17. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.
PROTECTION OF PERSONAL DATA
18. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures. These measures include, but are not limited to: minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly
19. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
20. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
21. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
22. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
23. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
24. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:
Contact No. : 6421 3220
Email Address : dpo@aspri.com.sg
EFFECT OF NOTICE AND CHANGES TO NOTICE
25. This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
26. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued engagement as an associate trainer and participation in our onboarding or assignment process constitute your acknowledgement and acceptance of such changes.
Effective date : 27/04/2026
Last updated : 27/04/2026