PDPA - Singlife

Data Protection Notice

This Data Protection Notice provides information on how Singapore Life Ltd. and Navigator Investment Services Limited (collectively referred as "Singlife") manage your personal data under the Personal Data Protection Act 2012. We are committed to treat all personal data in accordance with the relevant data protection laws of Singapore.

Jump to Section

• 1. Overview
• 2. Personal Data
• 3. Use of Cookies
• 4. Collection, Use and Disclosure
• 5. Collection, Use and Disclosure (Third Party Personal Data)
• 6. Purposes of Collection, Use and Disclosure
• 7. Marketing Consent
• 8. Withdrawal of Consent
• 9. Administration and Management of Personal Data
• 10. Your rights
• 11. DPO Contact
• 12. PDPA complaint
• 13. Update of Data Protection Notice

1. Overview

The Personal Data Protection Act or "PDPA" governs the collection, use and disclosure of personal data by private organisations. It contains various obligations relating to the Do-Not-Call Registry ("DNC Obligations") and the protection of personal data ("DP Obligations"). The DNC Obligations came into force on 2 January 2014 while the DP Obligations came into force on 2 July 2014.

Useful Links

• PDPC website
• DNC Registry website

We at Singlife take our responsibilities under Singapore's Personal Data Protection Act 2012 (the "PDPA") seriously. We also recognise the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.

This Notice is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

2. Personal Data

"Personal Data" is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include but not limited to names, identification numbers, contact information, financial information, policy information, medical records, photographs and video images.

We will collect your personal data in accordance with the written rules in the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

3. Use of Cookies

Refer to our Cookie Policy for more information.

4. Collection, Use and Disclosure

The personal data which we collect from you (or your authorized representative) may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data. You can see the full details of the purposes of collection, use and disclosure of your personal data in Section 6. Purposes of Collection, Use and Disclosure.

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear in section 6. Purposes of Collection, Use and Disclosure. However, we will notify you of such other purpose at the time of obtaining your consent, unless the collecting and/or processing of your personal data without your consent is permitted by the PDPA or by other written law.

In order to conduct our business operations smoothly, we may also be disclosing the personal data you have provided to us, to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the Purposes.

Generally all your personal data will be processed in Singapore. In certain situations, we may transfer your personal data to a country outside of Singapore for the Purposes as may be required on a need to know basis. In such an event, we will ensure that the receiving entities are bound by laws or contractual obligations for the protection of your personal data to a standard comparable to the Singapore PDPA.

The Internet is worldwide and if you are visiting this Website from outside Singapore your visit will necessarily result in the transfer of information across international borders. By visiting this Website and communicating electronically with us you are consenting to these transfers.

We respect the confidentiality of the personal data you have provided to us.  In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, for example where such disclosure without your consent is permitted by the PDPA or other laws.

While we endeavor to make our products / services available to you, we may not be able to provide products / services to you if you choose not to give us certain mandatory Personal Data that is necessary for us to provide the products / services. Similarly, while we endeavor to accede to your requests / instructions where possible, we may not be able to accept your request / instructions if you refuse to give us Personal Data that is necessary to process or administer your request.

5. Collection, Use and Disclosure (Third Party Personal Data)

When you provide personal data on a third party (e.g. spouse, children, parents), including and not limited to beneficiaries or lives assured, it is deemed you have obtained their consent to provide to us for a specific purpose.

 In any circumstances where you provide Singlife with personal data of a third party (e.g. your spouse, children, or parents), including and not limited to beneficiaries or lives assured ("Third Party Data"), you represent, warrant and undertake that:

• you have obtained the necessary and appropriate consent of that third party for the disclosure of their personal data to Singlife and the collection, use and disclosure of their personal data by Singlife for the Purposes; and
• all Third Party Data that you provide to Singlife are accurate and complete.
• You must notify Singlife in writing as soon as you become aware that any such Third  Party Data has since been updated or is no longer accurate; and
• if you become aware that any individual whose Third Party Data you have provided has partially or fully withdrawn his/her consent, you must notify Singlife in writing as soon as practicable. Upon receipt of such notice, Singlife reserves the right to discontinue or not provide any products, services, and/or transactions to you that are connected with such Third Party Data.

6. Purposes of Collection, Use and Disclosure

For the purposes of collection, use and disclosure of your personal data, please follow the respective links for details on how your personal data is or will be used.

• If you are an individual and;
  • if you apply for or are holding an insurance policy or an investment account with Singapore Life Ltd. or Navigator Investment Services Limited (collectively referred as "Singlife"), please refer to the Personal Data Protection Statement  below
  • if you have a MINDEF or MHA or POGIS insurance policy with us, please refer to the Personal Data Protection Statement here 
  • if you have an ElderShield supplement/ CareShield Life supplement policy with us, please refer to the Personal Data Protection Statement for ElderShield Supplement / CareShield Life Supplement policies here  
• If you are a corporation and you request for or have a group insurance policy with Singapore Life Ltd., you may be collecting and passing individual's personal data to/from Singlife. Please refer to the "Personal Data Protection Compliance Undertakings (By Corporate Prospect/Policyholder)" page here to see your obligations in relating to handling of personal data with Singlife.

Personal Data Protection Statement

In order to carry out our business, process, administer and/or manage your relationship, cover, policy, and/or account with Singapore Life Ltd. or Navigator Investment Services Limited (collectively referred as "Singlife"), we will have to collect, use and disclose your personal data for the stated Purpose(s). For the purposes of this Notice, Singapore Life Ltd.'s related group of companies include Navigator Investment Services Limited, Singlife Financial Advisers Pte. Ltd. and Professional Advisory Investment Services Pte. Ltd. 1. Personal Data Such personal data may include information or data provided by you or other parties in the application forms, other forms or from other sources, including existing data in our records and/or to be collected in the future. 2. Purposes Such personal data will be collected, used, disclosed and/or processed by Singlife (or Singlife related group of companies) for the purpose(s) (collectively referred to as the "Purposes") of:

a. responding to, processing and handling your queries, complaints, feedback, suggestions and requests;

b. providing and managing your access to our online services (whether these be presented on a website or in an application, and whether accessed via a computer or a mobile device), including the administration of user accounts and access credentials;

c. providing financial advice and product recommendations based on your financial needs analysis, where applicable;

d. administration of your policy, and/or account, which may include but is not limited to:

(i)   processing your application (ii) underwriting of the risk proposed (iii) requesting and collecting premiums or making any payments to or recoveries from you in connection with your policy and/or account; (iv)  providing information about your policy (v)  making changes or updates to your policy (vi)   reviewing or renewing or reinstating your policy (vii)  carrying out your instructions or responding to any enquiries by you (viii) authenticating, assessing, processing and settling your claim(s) made under the policy

e. administration of your account which may include but is not limited to:

(i) maintenance of your account (ii) performing or updating transactions on your account (iii) carrying out your instructions or responding to any enquiries by you

f.  processing or assisting in the processing of your payment transactions, including but not limited to facilitating the drawdown and transfer of your funds to third parties;

g. dealing in any matters relating to your policies and/or accounts (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages);

h. verifying your identity and any information you provide to us;

i.  training and quality control, including monitoring or recording your communications with us;

j.  managing your relationship with Singlife;

k. managing and facilitating your relationship with your authorised distributor(s) or representative(s);

l.  compiling statistics or conducting, surveys, research or data analytics for company or industry exercises and studies, to design, review or improve our products and services;

m. compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by Singlife and/or the industry;

n.  complying with applicable laws, regulations, rules, guidelines, schemes, undertakings or directions imposed by any regulator, government body, statutory body, law enforcement agency, industry body or dispute resolution body; 

o.  investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned;

p.  legal purposes such as enforcing obligations owed to us or seeking professional advice (including legal advice);

q. providing general information on product enhancements and services, which are relevant to your needs or policies (including increasing benefits, adding riders/supplements and/or insured lives);

r.  analysing your preferences and ensuring that the content, services and advertising we offer on our website, apps and/or portals are tailored to your needs and interests. Please refer to the section on Use of Cookies for details

s. informing you of products, services, offers, promotions, events or activities, that you may be interested in; subject to marketing consent that you have provided;

t. administering contests, lucky draws, promotions, events and competitions;

u. managing your records, including storage, archival, back up and/or destruction of personal data.

v. any other purposes which are reasonably related to the aforesaid.

Some of these purposes may apply or continue to apply after your relationship, policy and/or account with Singlife has ended or is no longer in force or active. 3. Disclosure

Such personal data of yours will be disclosed for the Purposes as described above by:

(a) Singlife to Singlife related group of companies (whether in Singapore or elsewhere in the world where such Singlife related group of companies are sited) and between each of them; and/or (b) Singlife (or Singlife related group of companies) to third party service providers, suppliers, agents, reinsurers, fund managers, intermediaries and/or other third parties (whether in Singapore or elsewhere), as and when relevant or necessary.  

Without limiting the generality of the foregoing, Singlife may also disclose such personal data of yours to the following parties for the following purposes:

(i) To medical organisations, insurance offices or organisations, reinsurers, credit agencies, dispute resolution bodies or investigators for underwriting, claims, reinsurance and compliance/audit purposes;

(ii) To your broker, financial adviser or representatives (including any new intermediary appointed by you or the company) to service and administer your plan or policy;

(iii) To related companies for the processing and administration of your plan or policy;

(iv) To banks, CPF agent banks, credit card companies, fund managers, other financial institutions, CPF Board or third party contractors for payment, collection or refund of any monies due or payable, for compliance purposes or upon their valid request;

(v) To third party vendors engaged by Singlife to perform processes required for the administration of your policy or account (e.g. data entry, printing and despatch of documents, claims administration etc.), for research, data analytics or to perform processes required to send marketing materials or messages to you, where applicable;

(vi) To related companies or third party vendors engaged by Singlife to store and maintain our data and documents (including storage for business recovery purposes);

(vii)  To any law enforcement agency, regulatory, government, statutory or industry body to comply with applicable laws , regulations or schemes or upon their valid request;

(viii) To related company or regional office or head office to comply with company policies and procedures or upon their valid request.

(ix) To legal and accounting firms providing services to Singlife; and

(x) To other third parties whether located in Singapore or outside of Singapore, for one or more of the abovementioned Purposes.  

Neither Singlife nor any of its officers shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to Singlife and/or any of its officers disclosing. 4. Consent

By applying for an insurance policy or an investment account with Singlife, accessing our website, using our mobile application, interacting with us or submitting information to us, you consent to Singlife and/or Singlife related group of companies:

(a) collecting, using, disclosing and/or processing the personal data mentioned above for the Purposes as described above; and (b) disclosing and transferring the personal data mentioned above to Singlife, Singlife related group of companies and their respective third party service providers, suppliers, agents, reinsurers, fund managers, intermediaries and/or other third parties, whether located in Singapore or outside of Singapore), for the Purposes as described above.

7. Marketing Consent

If you consent to marketing, Singlife, Singlife related group of companies and their service providers  may contact you to inform you about Singlife or Singlife related group of company products or services, special offers or other information which may be of interest to you. You can change your mind on the consent anytime. If you subsequently decide that you do not wish to receive marketing materials from us, all you need to do is to contact us.  Please note that even if you choose not to receive all marketing messages, you will still receive communications relating to follow up, servicing and other updates pertaining to your application, policies or investments. Alternatively, if you decide that you would like to receive the above marketing materials, you can also contact us to do so.

8. Withdrawal of Consent

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.

Request to withdraw marketing consent

• If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes as follows:
  • within 21 calendar days of your request to withdraw marketing consent for call and messages on any messaging platform (including SMS); or
  • within 30 calendar days of your request to withdraw marketing consent for mail, email and push notification.

• Withdrawal of marketing consent will not affect our ability to provide you with the products and services that you asked for or have with us.

Request to withdraw consent to the collection, use and disclosure of personal data for administration and servicing

• If you request to withdraw your consent for us to use your personal data for your insurance or account matters (for example matters relating to the servicing and administration of your insurance policy or your investment account), we will be unable to process, administer and/or manage your relationship, policy and/or account with us.
• This will affect our ability to provide you with the products and services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim.
•  In this regard, it may mean that we will not be able to continue with your existing relationship with us. To proceed with such withdrawal, you will be required to surrender or terminate all your policies or accounts with Singlife. This may be disadvantageous to you, as you may be losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.
• Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

9. Administration and Management of Personal Data

Accuracy

• We will take reasonable efforts to ensure that your personal data is accurate, complete and up-to-date, if your personal data is likely to be used by Singlife to make a decision that affects you; or disclosed to another organisation.
• However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data if you did not update us of the changes in your personal data.

Protection

• We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.
• However, we cannot assume responsibility for any unauthorised use of your personal data by third parties due to factors beyond our control.

Retention Limitation

• We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

10. Your rights

Request for access

• You may request to access your personal data currently in our possession or under our control by contacting us.
• A reasonable fee may be charged for the handling and processing of your requests to access your personal data.
• We will provide you with the relevant personal data 30 calendar days from such a request being made, or upon receipt of the fee, where applicable.
• If we are not able to respond to your request within this period, we will inform you within the 30 calendar days on when we will be able to respond to your request.

Request for correction

• You may request to correct the personal data currently in our possession or under our control by contacting us.
• We will: 

(a)  correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and

(b)  send the corrected personal data to every other organisation to which the personal data was disclosed by Singlife within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose: or

(c)  if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

11. DPO Contact

If you have any queries on this Notice or how we may manage, protect and/or process your personal data, you may contact our Data Protection Officers at:

Individual Life and Health Insurance Tel: +65 6827 9933 Email: [email protected]

General Insurance Tel: +65 6827 9933 Email: [email protected]

Group Insurance Email: [email protected]

Navigator Tel: +65 6827 7555 Email: [email protected] dollarDEX Tel: +65 6220 7890 Email: [email protected]

Office address 4 Shenton Way, #01-01 SGX Centre 2 Singapore 068807 

Operating hours 8.45am to 5.30pm, Mondays to Fridays, excluding Public Holidays.

Important note: "Please refer to our Contact Us section to be updated on any change to operating hours"

12. PDPA complaint

If you have any complaint or feedback about how we are handling your personal data or complying with the PDPA, please contact our Data Protection Officers at:

Individual Life and Health Insurance Tel: +65 6827 9933 Email: [email protected]

General Insurance Tel: +65 6827 9933 Email: [email protected]

Group Insurance Email: [email protected]

Group Insurance - MINDEF, MHA and POGIS Schemes Email: [email protected]

Navigator Tel: +65 6827 7555 Email: [email protected]

Office address 4 Shenton Way, #01-01 SGX Centre 2 Singapore 068807 

Operating hours 8.45am to 5.30pm, Mondays to Fridays, excluding Public Holidays.

Important note: "Please refer to our Contact Us section to be updated on any change to operating hours"

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 our organisation to handle. For example, you could insert the subject header as "PDPA Complaint". We will certainly strive to attend to any complaint or grievance that you may have speedily and fairly.

13. Update of Data Protection Notice

As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

We reserve the right to update the terms of this Data Protection Notice at our absolute discretion to be consistent with our business requirements, industry trends and/or changes in legal or regulatory requirements.

Any amended Data Protection Notice will be posted on our website and can be viewed at www.singlife.com/pdpa.

You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

The version of our Data Protection Notice which is displayed on our website takes precedence over all previous versions of our Data Protection Notice, Data Protection Statements and Data Protection Policies.  For avoidance of doubt, please note that this Data Protection Notice does not supersede or replace any other consents or authorisations you may have previously provided to us in respect of your personal data.

Last updated on 23 September 2022.