This Data Protection Notice (“Notice”) sets out the basis upon which the Bone Marrow Donor Programme (BMDP) (“we”, “us” or “our”) may collect, store, use, disclose or process personal data of registered marrow donors in accordance with the Personal Data Protection Act 2012 (“PDPA”).

APPLICATION OF THIS NOTICE

1. This Notice concerns all persons who have registered with BMDP as a marrow donor (“registered donor” or “you”).
2. This Notice applies to personal data in our possession or under our control, including personal data managed by third-party organisations engaged to collect, use, disclose or process personal data for our purposes.

TYPES OF PERSONAL DATA WE COLLECT

3. As used in this Notice, “personal data” means data, whether true or not, about a registered donor 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. Personal data which we may collect includes, without limitation, your:
   1. Full name (as stated in NRIC/Passport);
   2. NRIC or Identification Number;
   3. Date of birth;
   4. Contact details, including alternative contacts for situations where you are not reachable if you are found to be a potential match;
   5. Ethnic group;
   6. Health information; and
   7. A cheek swab sample for tissue typing to determine your Human Leukocyte Antigen (HLA) type.
5. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
6. Where personal data is submitted to us on behalf of another individual or concerns another individual other than yourself, you represent and warrant to us, that all the necessary consents have been obtained from the relevant individuals.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

7. We generally do not collect personal data unless (a) it is provided to us voluntarily by you directly in the course of or in connection with your registration as a marrow donor with BMDP; 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).
8. 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 registration.
9. Your personal data will be collected, processed and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
   1. Determining your HLA type;
   2. Adding you to the register; and
   3. Matching you to patients who need cell therapy and then getting in touch with you if you came up as a potential match.

WITHDRAWING CONSENT

10. 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. As a registered donor, you may withdraw your consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by writing to us at the contact details provided in this Notice.
11. 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 and effect your request within thirty (30) business days of receiving it.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your registration. We shall, in such circumstances, notify you before completing the processing of your request (as outlined above).
13. 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.

ACCESS TO AND CORRECTION OF PERSONAL DATA

14. You have the right to know what personal data we hold about you, use or disclose. You may write in to us at the contact details provided in this Notice to find out how we have been using or disclosing your personal data over the past one year.
15. You are also entitled to have incorrect personal data about you corrected or update any of your personal data which we hold in accordance to this Notice. You can also object to certain personal data about you being processed and request that processing of your personal data be limited.
16. Upon request, we will provide you the access to your personal data or other appropriate information on your personal data in accordance with the requirements of the PDPA.
17. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves.
18. We will respond to your access or correction request as soon as reasonably possible, or within 30 business days from the date we receive your request. If we are unable to do so within 30 business days, we will let you know and give you an estimate of how much longer we require.

PROTECTION OF PERSONAL DATA

19. 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 up to date antivirus protection, authentication and access control (such as good password practices, need-to-basis for data disclosure, etc,), password protection, data anonymisation, regular patching of operating system and other software, web security measures against risks and security review and testing performed etc.
20. When we disclose your personal data to third parties in line with the purposes mentioned in this Notice, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your personal data.
21. 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 DATA

22. We generally rely on personal data provided by you. In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data which you have provided to us. You may write in to us at the contact details provided in this Notice.  We will correct or complete your personal data as soon as reasonably practicable.

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

23. Where your Personal Data is to be transferred out of Singapore which may be necessary to determine your HLA type and the donor matching process, we will comply with the PDPA in doing so. We only make these transfers where we are completely satisfied that adequate levels of protection are in place to protect any information held in that country, or that the service provider acts at all times in compliance with applicable privacy laws.

RETENTION OF PERSONAL DATA

24. We may retain your 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.
25. 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 purposes for which the personal data were collected and are no longer necessary for legal or organisational purposes.
26. We dispose of or destroy such documents containing your personal data in a secure manner when the retention limit is reached, and it is reasonable to assume that the permitted purpose is no longer being served by their retention.
27. You will remain on the BMDP register until you are 60 years old, unless you wish to close your record on the register before that time.

CONTACTING US

28. If you have any question or feedback regarding this Notice, complaint relating to how we managed your personal data, or request relating to withdrawal of consent, access to or correction of personal data, you may contact us via this email address:donor@bmdp.org
29. Any request, query or complaint should include, at least, your name and contact information.
30. We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.

EFFECT OF NOTICE AND CHANGES TO NOTICE

31. This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
32. 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.
33. Your continued participation in our donor registration and matching process constitutes your acknowledgement and acceptance of such changes.

DRPE-DOC-04 │ Version 1.0 │ Effective Date:  5 May 2025