PRIVACY POLICY

 

DATA PROTECTION NOTICE

This Data Protection Notice (“Notice”) sets out the basis which the Group of companies, referring to Vodich Management Services Pte Ltd and related corporations, including any of Vodich Management Services’ subsidiaries, (“we”, “us”, or Our”) may collect, use, disclose or otherwise process personal data of our clients in accordance with the Personal Data Protection Act (“PDPA”).

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

As used in this Notice:

  • “clients” means an individual who:
    • has contacted us through any means to find out more about any services we provide; or
    • may, or has entered into a contract with us for the supply of any services by us;
  • “job applicant” means an individual who has submitted a job application to us through our website, job advertisements, or email;
  • “personal data” means data, whether true or not, about a client who can be identified: (a) from that data; or (b) from that data and other information which we have or are likely to have access.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include video footage from CCTV, information provided in your curriculum vitae (CV), name, date of birth, gender, nationality, state or province, place of birth, religion, race, marital status, mobile and home telephone numbers, email address, local or overseas residential address, driving licence number, driving licence expiry date, driving class and driving experience, educational background (including name of school or institute, highest qualification attained, and other courses or qualifications), language or dialect proficiency, past employment records, and referee details (including name, email address, contact number, occupation and company).

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

We collect your personal data when:

  • 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 you (or your authorised representative) have been notified of the purposes for which the data is collected, and you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
  • 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).

Important Notice on AML/CFT Compliance: Where personal data is processed to comply with statutory AML/CFT obligations, sanctions screening, or regulatory reporting under the ACRA CSP Act, The Group is not obligated to disclose the specific nature of this processing to the individual if doing so would contravene legal tipping-off prohibitions or prejudice an investigation.

We may collect and use your personal data for any or all of the following purposes:

For Job Applicants (Recruitment):
  1. Determining eligibility for initial employment, including the verification of references and qualifications;
  2. Security / Identity verification;
  3. Such other purposes as are reasonably required by the Company for meeting statutory and regulatory requirements.
For Clients:
  1. Collection of the particulars of (i) employees, (ii) clients, (iii) business partners, (iv) suppliers or (v) the contractors of clients for the purpose of provision of audit and assurance services, tax compliance and advisory services, business consultation, fund administration, KYC and advisory services or corporate secretarial services;
  2. Collection of particulars of client’s employees for the purpose of processing and preparing payroll and related services on behalf of clients;
  3. Communication with clients, including providing clients with updates on changes to services relating to addition, expansion, suspension of professional services and the terms and conditions;
  4. Processing client’s requests, complaints, or queries;
  5. Informing client on our services;
  6. Administering the relationship with any client;
  7. Conducting performance reviews and determining performance requirements;
  8. Conducting investigations into complaints or allegations by client relating to misconduct of any employee;
  9. Establishing a contact point in the event of an emergency (such as next of kin);
  10. Complying with applicable laws;
  11. Compiling directories;
  12. Creating and maintaining client’s profile in the company’s system for internal records and reference and filling of potential job openings;
  13. Keeping client updated on our company’s events;
  14. Taking photographs or videos for internal dissemination within our company and generating publicity materials for our services or recruitment events;
  15. Ensuring the security of company-held information;
  16. Responding to requests from Ministry of Manpower, Workplace Safety & Health, Singapore Civil Defense Force (“SCDF”) and relevant authority for submission of personal data information such as appointed / authorised person registration, investigation, medical examinations etc. as specified or required;
  17. Ensuring adherence to relevant laws, regulations, codes of practice, guidelines, or rules, and supporting law enforcement or regulatory investigations by governmental authorities;
  18. Any other purposes related to recruitment, employment or the business of the Company and its related corporations such as entry clearance to office or site clearance for projects / jobs; and
  19. Sharing of information with unaffiliated third parties (local and/or overseas) for the purposes outlined above.

We may disclose your personal data:

  • Where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you; or
  • 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; or
  • To Regulatory Bodies or Law Enforcement Agencies as required by law.

Where requests relate to AML/CFT investigations or Suspicious Transaction Reports (STRs), disclosures will be managed strictly by the designated Anti-Money Laundering Compliance Officer (AMLCO) to ensure confidentiality.

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).

Where consent is not obtained, we may collect, use or disclose personal data pursuant to an exception under the PDPA law such as to respond to an emergency that threatens the life, health and safety of an individual.

Where personal data is submitted on behalf of a third party (e.g. spouse, referees), it is the responsibility of the data provider to ensure that the necessary consent has been obtained.

In the event personal data is to be used for a new purpose, UCC will provide notice and obtain consent accordingly.

You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be in a position to process your job application or respond to queries. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in the withdrawal clause below.

WITHDRAWING YOUR CONSENT

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 via email to our Data Protection Officer (DPO) at dpo@prestigefiduciary.com.

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 all requests within ten (10) business days of receiving them.

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 able to continue providing our services to you as stated in Clause 5 of this notice.

Mandatory CDD Requirement: Where the withdrawal of consent relates to personal data required for mandatory Customer Due Diligence (CDD) under the ACRA CSP Act or MAS AML/CFT regulations, The Group must immediately cease providing services and terminate the business relationship, as it will be unlawful to continue. 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 by email to our DPO at dpo@prestigefiduciary.com.

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.

Where an individual validly exercises their right to erasure (and subject to the 5-year mandatory MAS/ACRA retention period for CDD records), The Group may still securely retain a minimal ‘suppression log’ or historical identifier. This is legally necessary to ensure compliance with ongoing AML/CFT screening, conflict of interest checks, and to prevent the unintentional re-onboarding of high-risk individuals or those previously exited for compliance reasons.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for 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 via email to our Data Protection Officer at dpo@prestigefiduciary.com.

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.

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 on when 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).

The right to access is subject to statutory exemptions. The Group reserves the right to refuse, restrict, or partially redact access requests where such disclosure would violate ‘tipping-off’ prohibitions under Singapore’s AML/CFT laws, or where restricted by the ACRA CSP Act or MAS regulations.

PROTECTION OF PERSONAL DATA

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 the principle of Data Protection by Design (e.g., minimised collection of personal data), authentication and access controls (e.g., secure passphrase policies, need-to-know 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, and 2 factor authentication (2FA) to secure access.

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

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 staff in charge of your account in writing or via email at the contact details provided below.

In compliance with MAS AML/CFT and ACRA CSP Act requirements, client data shall also be subject to periodic ongoing monitoring and CDD reviews (e.g., annually for high-risk profiles) to ensure the information remains materially accurate, up-to-date, and valid against current sanctions and PEP (Politically Exposed Person) lists.

RETENTION OF PERSONAL DATA

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. We have established a data retention policy that defines the retention period of your personal data.

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 conclude 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.

Where The Group is providing Fund Administration, Corporate Secretarial, or other regulated services, it is legally required under MAS and ACRA AML/CFT regulations to collect and retain full copies of NRICs, Passports, and other identification documents. These will be securely retained for the mandatory statutory period (typically 5 years). Notwithstanding general data minimization principles, The Group shall retain all CDD records, identification documents, transaction data, and business correspondence for a minimum period of 5 years following the termination of the business relationship or the completion of the transaction, as strictly mandated by the ACRA Corporate Service Providers (CSP) Act 2024 and applicable MAS AML/CFT regulations.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

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 BREACH NOTIFICATION

We take the protection of your personal data seriously and have put in place measures to prevent and manage data breaches. In the event of a personal data breach that is likely to cause significant harm to individuals or affects 500 or more individuals, we will:

  • Notify the Personal Data Protection Commission (PDPC) as soon as possible, and
  • Inform affected individuals as soon as practicable, in line with the requirements under the Personal Data Protection Act (PDPA).
Critical Regulatory Notice (MAS Risk Management): In the event of a severe personal data breach or cyber security incident affecting client data, the DPO must not only adhere to the PDPC’s 72-hour notification requirement, but must also notify the Monetary Authority of Singapore (MAS) no later than 1 hour upon the discovery of a relevant incident, in accordance with MAS Technology Risk Management and Cyber Hygiene notices.

We will provide details such as the nature of the breach, the data involved, actions taken to mitigate risks, and any steps individuals should take to protect themselves.

DATA PROTECTION OFFICER

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:

Email Address: dpo@prestigefiduciary.com

COMPLAINTS AND QUERIES

All complaints and queries shall be responded to within 14 business days. The response shall include an explanation of any remedial action taken by the Company.

EFFECT OF NOTICE AND CHANGES TO NOTICE

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.

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: 01 Mar 2026
Last updated: 01 Mar 2026

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