Personal Data Protection Policy (Youth Athletes/Parents/Guardians)

In this Personal Data Protection Policy (“Privacy Policy”), the words “NYSI”, “we”, “our” and “us” refer to the National Youth Sports Institute, an institute under Singapore Sports School Ltd located at 1 Champions Way, Singapore 737913 and 5D Stadium Lane, Singapore 397778.

BACKGROUND

In view of the enactment of the Personal Data Protection Act 2012 (“PDPA”), including all the amendments, regulations and notifications made thereunder, NYSI has put in place a personal data protection policy in relation to the collection, use and disclosure of prospective, current and/or past youth athlete (“Youth Athlete”)’s and/or parent/guardians’ personal data in youth athletes’ and/or parent/guardians’ dealings with NYSI. This Privacy Policy applies to personal data in NYSI’s possession or under NYSI’s control, including personal data in the possession of organisations which NYSI has engaged to collect, use, disclose or process for our purposes. For the purposes of this Privacy Policy, a reference to “Youth Athlete” includes “child” and “ward”, and where applicable, to “children” and “wards”; and a reference to “parent(s)” includes “guardian(s)”.

From time to time, it may be necessary for youth athletes and/or parents to supply NYSI with personal data about youth athletes and/or parents and other individuals for purposes in connection with Youth Athlete’s enrolment in NYSI.

In this Privacy Policy, “personal data” means information about youth athletes and/or parents, whether true or not, who can be identified: (a) from that data; or (b) from that data and other information to which NYSI has or is likely to have access. Such personal data may obtained from youth athlete applications and documents and any other personal information voluntarily provided by youth athletes and/or parents and processed by us.

Some examples of personal data about youth athletes and/or parents which NYSI may collect include the following (without limitation): name, age, citizenship, identification number, academic status and results, sport achievements, medical and disability information, residential address, mobile and residential telephone number, personal email address, bank account, photograph or video image and etc.

COLLECTION AND USE OF PERSONAL DATA

We generally do not collect youth athlete/parents’ personal data unless (a) it is provided to us voluntarily by youth athlete/parents or via a third party who has been duly authorised by such youth athlete/parent to disclose your personal data (your “authorised representative”) directly after (i) youth athlete/parents have been notified of the purposes for which the data is collected, and (ii) youth athlete/parents have provided consent (express, implied or deemed) to the collection, use and/or disclosure of youth athlete/parents’ personal data for those purposes, or (b) collection, use and/or disclosure of youth athlete/parents’ personal data without consent is permitted or required by the PDPA or any other law(s). We will seek your consent before collecting any additional personal data and before using youth athlete/parent’s personal data for a purpose which has not been notified to you (except where permitted or authorised by law). To avoid doubt, where our purposes of obtaining personal data is for direct marketing messages, we will obtain express consent from you, which will be obtained through the opt-in method.

PURPOSE

In accordance with our obligations under the PDPA, NYSI will only collect, use and/or disclose your personal data for purposes that a reasonable person would consider appropriate in the circumstances and that you have been informed of (where applicable).

NYSI will/may collect, use, disclose and/or process youth athletes’ and/or parents’ personal data for one or more of the following purposes:

a.     Processing youth athletes’/parents’ application, registration or event sign-up with us;

b.     Supporting and/or dealing with youth athletes’ training, competitions, health, medical needs, safety and welfare requirements such as but not limited to student support services, counselling, careers advices and health services;

c.     Administering and/or managing activities organised and/or held by NYSI. Please do note that photographs(s) or video images of youth athletes/parents may be taken during such activities and used, disclosed, processed and published in materials such as newsletters or other publications, yearbooks or any materials/books and you agree to the same;

d.     Administering and/or managing the use of facilities including but not limited to youth athletes accommodation needs, provision of Information Technology services and, training and recreation facilities;

e.     Displaying data youth athletes/parents have previously supplied to us and or Government agencies to speed up transactions and avoid the need for re-submissions;

f.      Contacting youth athletes/parents via different modes such as phone/voice call, short text message, email and/or postal mail for NYSI related matters such as but not limited to NYSI’s events, training and competition arrangement and fees and communicating with you in the event of public transport disruptions, emergencies or other extraneous circumstances such as national disasters, health pandemics, fire drills, evacuation drills and etc.

g.     Carrying out background checks, investigation and screen activities in accordance with legal or regulatory obligations that may be required by the Singapore law or that may have been put in place by us;

h.     Dealing with complaints related matters;

i.      Conducting disciplinary and security matters and/or arrangements. Please be informed there are surveillance cameras installed in SSP and NYSI for security reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently for the legitimate intends;

j.      Producing statistics and research for internal and/or statutory reporting and/or record keeping requirements and performing NYSI policy/process reviews;

k.     Carrying out research, analysis and development activities, including but not limited to data analytics, surveys and/or profiling to improve any of the NYSI’s programs;

l.      Responding to requests for information from local hospitals, embassies, public agencies, ministries, statutory boards or similar authorities;

m.   Complying with any government or regulatory requirements of any relevant jurisdiction to make disclosure;

n.     Conducting publicity and/or the development of promotional materials to showcase and market youth athletes’ achievements as a youth athlete supported by NYSI, publishing youth athletes image and/or personal data on public media platforms. Youth athlete/parents hereby grant NYSI permissions to use thier name, photograph, video images, personal story and information youth athletes/parents provide to NYSI in the Institute’s promotional materials and

o.     To contact youth athletes/parents for fund raising activities for NYSI selected causes by various modes of communication platforms including but not limited to phone/voice call, short text message, email, social media and/or postal mail.

The purposes listed in the above clauses may continue to apply even in situations where youth athletes’ association with NYSI has ended or altered in any way, and for a reasonable period thereafter (including, where applicable, a period to enable NYSI to enforce its rights under any contract with Youth athletes).

ATHLETE DEVELOPMENT AND PERFORMANCE SUPPORT

In respect of Athlete Development and Performance Support (“Support Services”), all such personal data, including (but not limited to) records, recordings of consultations, photography and videography of training and competition, will be done in strict confidence (where applicable), and access will be restricted to directly relevant personnel (e.g. sport scientist, coach(es), General Manager) and senior NYSI management. All other relevant personnel will be informed on a need-to-know basis only. Youth athletes will be informed prior to any Support Services being conducted, and consent for any potential disclosure of personal data shall be in accordance with this Privacy Policy.

The findings obtained from the Support Services will be shared with youth athletes’ coach(es).

As part of continual learning and sharing of information, NYSI may present the findings at conferences and public in journals so that other interested people may learn from our findings. In such instances, clearance from an institutional review board would be sought. In these instances, due care will be taken to ensure that all data is anonymised and that no personal data will be disclosed.

DISCLOSURE TO THIRD PARTIES

NYSI may be required to disclose youth athletes’ and/or parents’ personal data to third parties which would be processing youth athletes’ and/or parents’ personal data for one or more of the above purposes. These third parties include but are not limited to the following:

(a)   Organisations including (without limitation) National Sport Associations with which we are collaborating for one (1) or more of the abovementioned purposes;

(b)   Individuals, Organisations, Universities and/or any Government Agency/Authority who have provided youth athletes with scholarships, financial assistance, awards, medals or prizes during the period of youth athletes’ studies in NYSI and/or who may request for information relating to youth athletes’ progress and result as a youth athlete supported by NYSI;

(c)   Any service providers engaged by NYSI who process youth athletes’ personal data on behalf of NYSI including, but not limited to, hospitals, medical centre(s), Outward Bound Singapore and those which supply administrative services to NYSI such as manufactures of award medals, plagues, trophies, information technology companies and printers of NYSI publications; and

(d)   Organisations and/or educational institutions which are involved in exchange programmes with us.

We may/would not be able to process youth athletes with us for grants, bursaries and scholarships whether they are from us or external organisatons should youth athletes/parents fail to supply us with certain personal data. Likewise, NYSI may/would not be able to effectively administer our relationship with youth athletes and/or parents.

Unless otherwise permitted under the PDPA, NYSI will not disclose youth athletes’ and/or parents’ personal data to any extent, which we will determine in good faith, to be greater than necessary.

WITHDRAWING CONSENT BY YOUTH ATHLETE AND/OR PARENTS

The consent that youth athletes’/parents provide for the collection, use and disclosure of youth athletes’ and/or parents’ personal data will remain valid until such time it is being withdrawn by you in writing. Youth athlete/parents may withdraw consent (in part or in whole) and request NYSI 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 NYSI’s Data Protection Officer.

Upon receipt of youth athlete/parents’ written request to withdraw consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with the relevant youth athlete and/or parent) for the request to be processed and, if necessary, for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect the relevant youth athlete’s and/or parent’s rights and liabilities to us. In general, we shall seek to process such requests within ten (10) business days of receiving it.

Withdrawal of consent does not affect NYSI’s 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

Youth athletes/parents have the right to request access to, update and/or correct their personal data held by us. If you wish to make (a) an access request for access to a copy of the personal data which NYSI holds about you or information about the ways in which NYSI uses or discloses your personal data, or (b) a correction request to correct or update any of your personal data which NYSI holds, you may submit your request in writing or via email to NYSI’s Data Protection Officer.

A fee may be charged for an access request. We will inform you of the fee before processing the request.

Depending on the request that is being made, NYSI will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents (or systems) themselves.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 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.

Where we are not required to provide you with any personal data or make a correction requested by you under the PDPA, any such request for the same shall be refused. In such situations, and in accordance with our obligations under the PDPA, we will preserve, for not less than 30 days after the date of refusal or such other prescribed period, a copy of the personal data concerned. Such copy of the personal data concerned shall be a complete and accurate copy of the personal data concerned.

PROTECTION OF PERSONAL DATA

To safeguard youth athletes/parents’ 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

Youth athletes/parents 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

NYSI generally relies on personal data provided by youth athletes/parents (or your authorised representatives). In order to ensure that the personal data is current, complete and accurate, you should inform the Human Resource Department of any changes to your personal data in writing.

RETENTION OF PERSONAL DATA

NYSI may retain youth athletes’ and/or parents’ 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.

NYSI will cease to retain youth athletes’/parents’ personal data 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. At such point in time, NYSI will either cease to retain the documents containing personal data or we may remove the means by which the personal data may be associated with particular individuals (that is, to anonymise the data). In the latter case, NYSI will take steps to minimise the risks of re-identification of the individual involved.

TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE

We generally do not transfer personal data to countries outside of Singapore. However, if we do so, we will obtain youth athlete’s and/or parent’s consent for the transfer to be made and we will take steps to ensure that such personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA BREACH NOTIFICATION

In the unlikely event that NYSI suffers a Data Breach (defined below) in relation to personal data, NYSI will assess whether the Data Breach is notifiable, and notify the affected individuals and/or the Personal Data Protection Commission (“PDPC”) where it is assessed to be notifiable. To be clear, a Data Breach within NYSI does not trigger any obligation to notify affected individuals and/or the PDPC.

For the purposes of this section, “Data Breach” in relation to personal data means (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of personal data; or (b) the loss of any storage medium or device on which personal data is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal data is likely to occur.

EFFECT OF POLICY AND CHANGES TO POLICY

From time to time, we may update this Privacy Policy without any prior notice to ensure that our Privacy Policy is consistent with regulatory changes. Should any revision(s) be made to this Privacy Policy, updates will be published on our public site (https://www.nysi.org.sg/about-nysi/personal-data-protection-policy-youth-athletes-parents-guardians). Subject to your legal rights in Singapore, the prevailing terms of the Privacy Policy shall apply.

This Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Privacy Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.

QUERIES

If Youth athletes/parents have any questions relating to our collection, use, disclosure and/or process of your personal data or the matters set out in this document, please contact our Data Protection Officer.