The above video was taken by a TWC2 volunteer as she was on her way to TWC2’s Cuff Road Project in the Little India area. The Cuff Road Project is TWC2’s programme providing free meals to migrant workers with salary, injury or other cases, who are left unemployed and without income.

Our volunteer was walking past a law office when she noticed bundles and bundles of case documents lying on the five-foot way, fully accessible to any member of the public. This law office is well known to TWC2 as one which handles, almost exclusively, work injury claims. It takes on migrant workers’ claims and takes a cut of the compensation amounts that are finally awarded for permanent disability.

Work injury claims are typically processed by the Ministry of Manpower and insurance companies with no need for legal representation. Lawyers seldom have to do much work beyond filling in an online form or two, and for that, they can charge migrant workers hundreds or thousands of dollars.

Like MOM, TWC2 regularly tells workers that they do not need to engage lawyers for their claims. But the law firms that see work injury claims as their bread and butter business tend to hire “representatives” who speak migrant workers’ languages and thus present themselves as more understanding of their plight and culturally sympathetic to their needs. Workers place more trust in those who come from similar ethno-linguistic backgrounds. And so this business model is hard to shake.

Our volunteer who took this video was aghast at how cavalier the law office was about personal data within those bundles of documents. Of course she didn’t want to rummage through them to see for herself; doing so and looking at personal data, merely out of curiosity, would be an ethical gray area. But since these are almost surely injury claim documents (this law office specialises in such work) one can assume that loads of personal data would be in those papers.

And there they were, out of the street.

What happened when TWC2 moved office?

TWC2 faced the herculean task of sorting and disposing documents when we moved office last February. Administration officer Christine Scully, who was in charge of the move, explained that there was “a backlog of old digital and physical documents”, including financial documents that did not need to be kept for more than six years.

“All the staff and Executive Committee members did their part to go through whatever we thought was unnecessary for us” to take to the new office, she said.  “We put them aside in cartons, labelled them, and hired a company to dispose them for us in a proper way,” she added.

According to a 2017 guide by the Personal Data Protection Commission Singapore, ‘disposal’ is defined as the overall process of transforming or destroying information in a way that ‘renders it unreadable (for paper records) or irretrievable (for electronic records)’. It added that disposal ‘should not be taken lightly’ and in fact, needs to be ‘well managed and controlled throughout the entire data life cycle’, from collection, maintenance, and archival to disposal.

Under the law, physical documents are required to be disposed in one of these three ways – incineration, shredding, or pulping. For data stored on electronic media, companies are required to use specialised software tools to securely erase all personal data contained in the media. When secure deletion is not possible, companies are required to physically destroy the electronic media through ways including degaussing and incineration of faulty hard disks.

TWC2 did just that. After obtaining three different quotes, we hired a third-party service provider named Arkiva for the disposal. After the work was done, Arkiva shared ‘before’ and ‘after’ pictures of the disposed cartons with Christine, as well as certification to officially confirm the number of cartons they collected from TWC2 and destroyed.

“There are many companies that work according to what the government requires – proper disposal. It wasn’t very hard to find their contact; you can find them online,” Christine said.

Indeed, an online search by this writer using the phrase ‘professional document disposal companies in Singapore’ found at least eight companies. At the same time, the search phrase ‘professional shredding company Singapore’ showed listicles of the best shredding services in Singapore.

Having had the experience with proper data disposal, TWC2 plans to engage Arkiva in future should we require disposal of electronic media. “Currently, we don’t have many physical documents. We have a shredder in the office and shred as and when required; we don’t accumulate documentation that is unnecessary. If there is an accumulation of digital documentation that need to be disposed, we know exactly where to go and what is expected for the disposal to be effective,” Christine explained.

According to Christine, TWC2 takes data protection and privacy very seriously, especially with the ongoing scams these days. Statistics from the Singapore Police Force released in February 2024 showed that scams and cybercrime continue to be a key concern. In fact, the number of such cases rose by 49.6% to 50,376 in 2023, compared to 33,669 cases in 2022.

“We are dealing with the public – donors and volunteers, and we must respect their privacy. We only collect whatever is necessary and ensure the information is kept very private, only what is needed for us to move forward. We are very careful about what we do, what data we collect, and what we keep,” Christine said.