Personal data protection policy

Posted by on July 2, 2014 in


Transient Workers Count Too, in conformity with the Personal Data Protection Act (2012), is pleased to publish this statement explaining our policies:


It is up to each donor how much personal information he/she wishes to provide TWC2. Donations that do not come with any personal information will be treated as anonymous donations.

Where a donor provides some information about himself/herself (e.g. so we can send a receipt), unless otherwise curtailed by a specific request, such information will be stored in TWC2’s information system and may be used when we make future appeals.

Under normal circumstances, no situation is expected to arise when we will need to share such donor information with parties outside of TWC2.

One possible exception may be in a scenario like this: A donor is donating gifts in kind to TWC2 but delivered to a mutually agreed third-party location. In such a circumstance, TWC2 may need to provide that third party with a name, telephone number or email address in order to co-ordinate delivery. No other information will be divulged.

Members and volunteers

Members and volunteers will be asked for enough information about themselves to enable the organisation to know how to contact them, their availability and the skill sets they can offer. We will also need to have members’ and volunteers’ addresses and national identification numbers so that there is traceability and accountability since volunteers will get to handle selected client information from time to time. It would be irresponsible of the organisation to allow volunteers to handle case information when we do not have definitive knowledge of volunteers’ identities.

The organisation may use the information so collected to keep members and volunteers abreast of developments and news at periodic intervals, and to call upon volunteers for assistance when needed.

We do not envisage any situation in normal circumstances (exception below) when TWC2 will need to divulge personal information about members and volunteers to third parties.

The exception is when a volunteer is accompanying a client to a hospital, the Ministry of Manpower or other appointment. TWC2 may need to inform that other organisation to expect the volunteer at a certain date and time (e.g. a hospital’s medical social worker wishes to speak with the volunteer), and in the interest of good communication and smooth coordination, we may share the volunteer’s name and telephone number with the other party.


TWC2 collects quite extensive personal identity and case information from our foreign worker clients, including medical information. However, we do not collect, store or use such information unless the client has first been appraised of the need, and has given his or her consent.

We have explanatory notes in the languages commonly spoken by foreign workers, so that they can read for themselves and understand the significance of what they are consenting to. For those speaking uncommon languages, our staff and volunteers will carefully and patiently explain the meaning and purpose of consent to them in simple English.

The vast majority of clients will be asked to give consent in writing. However, some clients only reach us through our helpline (telephone). In such situations, we will explain verbally the need for consent and obtain it verbally as well.

Since TWC2 cannot provide any assistance to a client unless we know enough to assess and advise on a case – this includes eligibility for benefits given out by TWC2 – a worker is not admitted as a client unless that worker gives consent.

The consent forms that clients sign make clear the purposes of information so collected: internal discussion within TWC2 about his/her case; communication with the government and other organisations that will help progress the case; and research and public communication when we feel that these would be of help to the worker or other workers with similar problems.

Nevertheless. TWC2 will remain highly judicious in sharing such information with external parties. Even when some details are communicated, they will be restricted to only such details as are germane to that specific purpose (even if the worker has given us broader consent), and we will expect recipients of such information to be equally bound by professional ethics to safeguard the information.

From time to time, TWC2 receives personal information about workers from third parties (e.g. from hospitals telling us about a patient in need of TWC2 assistance, from police trying to trace a worker, well-wishers asking us to help a worker they’ve met) and our operating assumption is that such unsolicited transfer of information to us comes either with deemed consent or explicit consent obtained by those third parties, or that such transfer of information is within the allowed purposes as listed in the Second Schedule of the PDPA(2012), particularly 1(a), (b), (f), (m) and (q). TWC2 will hold, use and safeguard such received information the same way we hold our clients’ information.

Withdrawal of consent

With respect to Section 11(3) of the PDPA(2012), TWC2 designates the Secretary of the society to be the individual responsible for ensuring that the organisation complies with the Act.

With respect to Section 16(1) of the PDPA(2012), any donor, volunteer, client or other person whose information we have collected may write to the organisation (Attention: Secretary), giving reasonable notice, to withdraw any consent given or deemed to have been given.

Within a practical period of time, TWC2 will, in accordance with the Act, cease further collection, use or disclosure of such data, and will make reasonable efforts to inform all other parties, with whom TWC2 had earlier shared such data, to likewise cease. However, as allowed under Section 25(b) of the Act, not all information may be deleted. Information that is essential for legal and business purposes will be retained, even if no longer used.

For example, donor’s identity and copies of receipts sent cannot be deleted without compromising audit integrity. Similarly, when clients have received benefits (with value) from TWC2, we cannot delete those records without consequences to audit. Volunteers’ identity cannot be deleted when certain actions and duties they performed are closely intertwined with client case records, and when deletion may eviscerate those records and correspondingly harm clients’ interests.

However, on receipt of a cessation request, no further contact with the requestor will take place (save to confirm or clarify the request) nor further use be made of whatever essential information we lawfully retain.