pdpc_decisions_version_detail (view)
1 row where nature = "Protection, Purpose Limitation"
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_commit_at | _commit_hash | _id | _item | _version | _commit | description | tags | date | pdf-url | nature | title | url | timestamp | pdf-content | decision | _item_full_hash | _changed_columns |
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2023-10-01T11:02:10+08:00 | fbd32491db44d3d0c97aa12a99cefd61ec954264 | 178 | 178 | 1 | 952 | A warning was issued to Galaxy Credit and Investments for failing to make reasonable security arrangements to protect the personal data of its borrowers, and using personal data not for a purpose that a reasonable person would consider appropriate in the circumstances. | [ "Protection", "Purpose Limitation", "Warning", "Finance and Insurance", "Licensed moneylender" ] |
2018-09-25 | https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Commissions-Decisions/Grounds_of_Decision_Galaxy_Credit_and_Investments_Pte_Ltd_250918.pdf | Protection, Purpose Limitation | Breach of the Protection and Purpose Limitation Obligations by Galaxy Credit and Investments | https://www.pdpc.gov.sg/all-commissions-decisions/2018/09/breach-of-the-protection-and-purpose-limitation-obligations-by-galaxy-credit-and-investments | 2018-09-25 | PERSONAL DATA PROTECTION COMMISSION [2018] SGPDPC 22 Case No DP-1803-B1886 In the matter of an investigation under section 50(1) of the Personal Data Protection Act 2012 And Galaxy Credit & Investments Pte. Ltd. … Organisation DECISION Galaxy Credit & Investments Pte. Ltd [2018] SGPDPC 22 Yeong Zee Kin, Deputy Commissioner — Case No DP-1803-B1886 25 September 2018 Background 1 Is it appropriate for a licensed moneylender, or any organisation, to attach a photograph of a debtor to a letter demanding payment of a debt and leave both the photograph and letter at the residence of the debtor? What is the objective or purpose of such a practice? If the Organisation had considered these questions, the unauthorised disclosure in this matter may very well have not occurred. 2 The facts in this matter are straightforward and are not in dispute. On 16 March 2018, the Registry of Moneylenders & Pawnbrokers, Ministry of Law (“ROMP”) informed the Personal Data Protection Commission (the “Commission”) that the Organisation had sent three letters of demand, each with a photograph of a borrower, [Redacted] (Replaced with “Mr T”), to the residence of another borrower, [Redacted] (Replaced with “Mr W”). The Commission proceeded to investigate into an alleged breach of the Personal Data Protection Act 2012 (“PDPA”). Galaxy Credit & Investments Pte Ltd [2018] SGPDPC 22 Material Facts 3 The Organisation is a licensed Moneylender. As part of their business, the Organisation issued letters of demand (“LODs”) to borrowers who defaulted on the repayment of their loan. These LODs would be delivered to the defaulting borrowers by a third-party debt collector engaged by the Organisation. Prior to each delivery, the Organisation would provide their debt collector with the LOD and a photograph of the borrower. According to the Organisation, the purpose of providing a photograph was to help the debt collector correctly identify the borrower. 4 The Organisation instructed the debt collectors to attach the photograph to the LOD … | Warning | 88b0d7aaedbad54d85d3b73d6a27e2cd7d69902d | [ "pdf-content", "timestamp", "decision", "pdf-url", "tags", "nature", "url", "title", "date", "description" ] |
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CREATE VIEW pdpc_decisions_version_detail AS select commits.commit_at as _commit_at, commits.hash as _commit_hash, pdpc_decisions_version.*, ( select json_group_array(name) from columns where id in ( select column from pdpc_decisions_changed where item_version = pdpc_decisions_version._id ) ) as _changed_columns from pdpc_decisions_version join commits on commits.id = pdpc_decisions_version._commit;