DATA PROTECTION NOTICE FOR CUSTOMERS

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 its customers 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 Notice 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.

PERSONAL DATA

1. As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more about the courses or services we provide/offer, or (b) may, or has, entered into a contract with us for the courses or services provided or offered by us; and

“personal data” means data, whether true or not, about a customer 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.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, race, gender, date of birth, photograph and employment information.

3. 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

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) 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).

5. We may collect and use your personal data for any or all of the following purposes, which are not exhaustive

(a) verifying your identity;

(b) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(c) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

(d) to administer the course registration, including to contact you and/or your employees for pre-course and post-course administration required by the course accreditation bodies;

(e) To provide the following personal information to SSG to facilitate the TRAQOM initiative for TRAQOM surveys;

(f) processing payment or credit transaction;

(g) Any other purposes for which you have provided the information;

(h) managing your relationship with us;

(i) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(j) collecting and processing biometric and/or image data through our CCTV systems upon your entry into our office premises for administrative and human resource–related purposes within our organisation, including but not limited to managing and granting access to our premises and investigating any acts, defaults, or suspected misconduct

(k) any other incidental business purposes related to or in connection with the above.

(l)To be notified of newsletter, promotion, offer and new dates for courses

6. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or

(b) to disclose these data to the relevant government agencies, including but not limited to, Workforce Singapore (WSG) / SkillsFuture Singapore (SSG) / Ministry of Manpower (MOM) and to our vendors for the development, maintenance and troubleshooting of our training management system.

(c) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.

7. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under a contract with you).

8. 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:

(a) Process application for course registration

(b) Issue a certificate of completion or professional accreditation upon course completion

(c) Provide the necessary login credentials to access ASPRI-IPI platforms (Training Management System and Learning Management System).

(d) Process government subsidies or training grants (e.g., SkillsFuture or employer-sponsored funding) that require verified personal details

(e) Respond to inquiries, feedback, or support requests

(f) Provide updates or send promotional materials tailored to the interests.

(g) Facilitate post-training support, including follow-up resources

(h) Contact emergency personnel when required

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

9. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of ASPRI-Institute of Process Industry (ASPRI-IPI) or another person. In relying on the legitimate interests exception of the PDPA, ASPRI-Institute of Process Industry (ASPRI-IPI) will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

10. 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

11. 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 for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided

12. 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.

13. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

14. 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.

ACCESS TO AND CORRECTION OF PERSONAL DATA

15. 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 about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

16. 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.

17. 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 request within thirty (30) days after receiving your 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).

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 such as 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.

DATA BREACH NOTIFICATION

20. In our capacity as a data controller, if a data breach occurs that is likely to result in significant harm to affected individuals or is of a significant scale, we will notify the Personal Data Protection Commission (PDPC) within three (3) calendar days. If the data breach is likely to result in significant harm to you, we will also notify you directly as soon as practicable to provide information on the nature of the breach, the steps we are taking to contain and mitigate it, and the recommended actions you can take to protect yourself.

21. Where we act as a data intermediary or data processor processing personal data on behalf of another organisation, we will notify that respective organisation (the data controller) without undue delay upon becoming aware of any suspected or confirmed data breach. This ensures the data controller can promptly assess the incident and fulfill their own statutory data breach notification obligations. 16. Where a privacy or security breach was caused by a security failure, we shall take immediate steps to correct/address the security failure.

ACCURACY OF PERSONAL DATA

22. 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

23. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

24. 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 purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

 25. 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 we 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

26. 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. 64213223     

Email Address : dpo@aspri.com.sg

EFFECT OF NOTICE AND CHANGES TO NOTICE

27. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

28. 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 use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 27/04/2026

Last updated : 27/04/2026