All Board members and staff are required to comply with the charity’s conflict of interest policy.

The Board has put in place documented procedures for Board members and staff to declare actual or potential conflicts of interests on a regular and need-to basis.

Board members also abstain and do not participate in decision-making on matters where they have a conflict of interest.

SBC’S Personal Data Privacy Notice

1. Privacy Commitment

   1. We at Singapore Book Council Limited (SBC) are committed to safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data.
   2. This Data Protection Notice (“ Notice”) sets out the basis which Singapore Book Council Limited (“ we”, “ us”, or “ our”) may collect, use, disclose or otherwise process personal data of our customers 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.
2. Personal Data

   1. “Personal Data” is defined under 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.
   2. We will collect your personal data in accordance with the PDPA either directly from you or your authorised representatives, and/or through our third party service providers (e.g. ticketing agents or survey companies). 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. As used in this Notice:
      “ customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
      
      “ personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
   4. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number and other key information that is required for the ease of communications.
   5. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
3. Collection, Use and Disclosure of Personal Data

   1. We generally do not collect your personal data unless (a) 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 (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) 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).
   2. We may collect and use your personal data for any or all of the following purposes:
      • dealing with and/or carrying out administrative matters on your ticket purchases, processing your sign-ups/registrations for festivals, workshops, events, activities, venue bookings, mailing lists etc;
      • responding to, handling, and processing queries requests, applications, complaints, and feedback from you;
      • processing payments or credit transactions;
      • providing you with information on our upcoming events, festivals, workshops, award ceremonies where you have specifically requested to receive such information;
      • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
      • processing, facilitating and maintaining your relationship with SBC as a programme participant, volunteer, donor and/or employee;
      • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
      • any other purposes for which you have provided the information.

      (collectively, the “Purposes”)

   3. As for other purposes for which we may use, disclose or process your personal data that has not appeared above, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
   4. In order to conduct our business operations more smoothly and to fulfil the above-said Purposes, 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 sponsors, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes.
   5. Such third party service providers, agents and/or affiliates or related corporations and/or sponsors and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Without limiting the generality of the foregoing, such third party include:
      • any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf to conduct market research, data analytics, data mining, data profiling and customer satisfaction surveys to enable SBC to improve our programmes and events;
      • any other purposes that we notify you of at the time of obtaining your consent.
   6. Where we disclose your personal data to third parties, we will employ reasonable measures to ensure the protection of your personal data, such as imposing suitable contractual clauses on such third parties or disclosing only to reputable organisations.
   7. 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 the goods and services requested by you; and
      • to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations.
4. Withdrawing Your Consent

   1. 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 in writing or via email to our Data Protection Officer at the contact details provided below in clause 10.
   2. 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 your request within three (3) business days of receiving it.
   3. 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 in a position to continue providing our goods or services to you and 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 in the manner described above.
   4. 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.
5. Access to and Correction of Personal Data

   1. If you wish to make (a) an access request for access to 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 or via email to our Data Protection Officer at the contact details provided below.
   2. 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.
   3. We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) 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 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 (except where we are not required to do so under the PDPA).
6. Protection of Personal Data

   1. 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 security measures.
   2. 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.
7. Accuracy of Personal Data

   1. 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 Data Protection Officer in writing or via email at the contact details provided below.
8. Retention of Personal Data

   1. 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.
   2. 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 assume 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.
9. Transfers of Personal Data Outside of Singapore

   1. 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.
10. Data Protection Officer

    1. 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, in the following manner:
       
       

       Name of DPO	: Celine Chow
       Contact No	: 6342 5119
       Email Address	: [email protected]

11. Effect of Notice and Changes to Notice

    1. 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.
    2. 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.

The charity has a reserve policy for long-term stability of the operations and it ensures that there are sufficient resources to support the charity in the event of unforeseen circumstances. As a general rule of thumb, the charity has 1 year of operational expenditure kept as reserves. The reserve level is reviewed yearly by the Board to ensure that the reserves are adequate to fulfil the charity’s continuing obligations. SBC invests its reserves only in fixed deposits.

Singapore Book Council (SBC) is committed to conducting its organisation with honesty and integrity at all times. If, at any time, the commitment is not respected or appears to be in question, SBC will endeavour to identify and remedy such situations. Therefore, it is the organisation’s policy to ensure that when a person has reasonable grounds to believe that an employee, manager or any other person related to the organisation has committed, or is about to commit, an offence that could harm the organisation’s business or reputation, it denounces the wrongdoers in question.

The whistleblowing policy has been put in place to:

• Encourage employees, partners or managers to disclose this information or behaviour;
• Protect complainants from reprisals;
• Treat all parties to an investigation in a fair and equitable manner;
• To ensure confidentiality as much as possible;
• Take corrective and disciplinary action if wrongdoing is discovered.

The purpose of this whistleblowing policy is to encourage current and former employees, contractual third parties or partners to communicate events that raise serious concerns about SBC. SBC encourages and will support staff who report illegal practices or individuals who violate the organisation’s policies.

This policy applies to all employees, contractual third parties, partners or volunteers to report misconduct or suspected misconduct, including fraud and financial impropriety to the SBC Board of Directors. This includes misconduct such as but not limited to:

• Providing false or misleading, information or withholding material information on SBC’s financial statements, accounting, auditing or other financial reporting fraud or misrepresentation;
• Pursuit of material benefit or advantage in violation of SBC’s Conflict of Interest Policy;
• Misappropriation or misuse of SBC resources such as funds, supplies or other assets;
• Unauthorised alteration or manipulation of company files;
• Destroying, altering, mutilating, concealing, covering up, falsifying, or making a false entry in any records that may be connected to an official proceeding.

Reporting Channels:

The channels for reporting is via:

• Email to [email protected]
  Attn: Whistleblowing governance officer
  [to include the name of contact person, contact number and email address]
• Mail to
  Singapore Book Council
  90 Goodman Road, Goodman Arts Centre, Blk E #03-32.
  Singapore 439053
  Attn: Whistleblowing governance officer
  [to include the name of contact person, contact number and address]

When making a report, the whistleblower should as far as possible include the following information:

• Date, time and place of the actions/transactions;
• Identity and particulars of the parties involved;
• Circumstances leading to the improprieties; and
• Any other relevant information or documentation that would assist in the evaluation of the report/incident.

Whistleblowers making any such reports should ensure that they do so in good faith and in the best interest of SBC and not with any malicious intent. Whistleblowers may be the subject of disciplinary or other legal action if the reports or allegations are malicious, frivolous or simply to cause anger, irritation, or distress.

For all reports, including those raised anonymously, the charity will maintain a proper register of all concerns received. It will send an acknowledgement of receipt to the whistleblower, if the identity is provided, and all reported concerns     will be assessed by the charity. The whistleblower should also be provided with subsequent information on the follow-up processes (e.g. assessment, investigation and action) as appropriate.

All information provided will be kept strictly confidential to protect the whistleblower from reprisal, discrimination and other adverse consequences.