PDPA

Overview

This overview provides information on how Aviva Ltd and Navigator Investment Services Limited (collectively referred as "Aviva") manage your personal information under the Personal Data Protection Act 2012.

We are committed to treat all personal data in accordance with the relevant data protection laws of Singapore.

DATA PROTECTION POLICY

We at Aviva take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officers below:

Individual Life and Health Insurance

Ms Sue Uan
Tel: +65 6827 9933
Email: cs_life@aviva-asia.com

 

General Insurance

Mr Remus Sim
Tel: +65 6827 9966
Email: personal_insurance@aviva.com.sg

 

Group Insurance

Ms Che Jam
Email: ebh_enquiries@aviva-asia.com

 

Navigator

Ms Lynette Foo
Tel: +65 6827 7555
Email: service@navigator-asia.com

 

Office address
4 Shenton Way, #01-01 SGX Centre 2 Singapore 068807

Operating hours
8.45am to 5.30pm, Mondays to Fridays, excluding Public Holidays.

1. INTRODUCTION TO THE PDPA

1.1 “Personal Data” is defined under the 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. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2 We will collect your personal data in accordance with the PDPA. 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.

2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data. You can see full details of the purposes of collection, use and disclosure of your personal data (collectively, the “Purposes”) on the Collection, Use and Disclosure page. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear in the Collection, Use and Disclosure page. However, 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.

2.2 In order to conduct our business operations smoothly, 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 other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations 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.

2.3 Generally all your personal data will be processed in Singapore. In certain situations, we may transfer your personal data to a country outside of Singapore for the above Purposes as may be required on a need to know basis. In such an event, we will ensure that the receiving entities are bound by laws or contractual obligations for the protection of your personal data to a standard comparable to the Singapore PDPA.

3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1 We respect the confidentiality of the personal data you have provided to us.

3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following: 

(a)cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;

(b)cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;

(c)cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

(d)cases in which the disclosure is necessary for any investigation or legal proceedings;

(e)cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;

(f)cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or;

(g)where such disclosure without your consent is permitted by the PDPA or by law.

3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg.

3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.

4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1 You may request to access and/or correct the personal data currently in our possession or under our control by contacting us.

4.2 For a request to access personal data, we will provide you with the relevant personal data 30 calendar days from such a request being made.

4.3 For a request to correct personal data, we will: 

(a)    correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and

(b)    subject to paragraph [4.4], we will send the corrected personal data to every other organisation to which the personal data was disclosed by Aviva within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

4.4 Notwithstanding paragraph [4.3(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data.

5. REQUEST TO WITHDRAW CONSENT

5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us.

5.2 If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days of your request.

5.3 However, if you request to withdraw your consent for us to use your personal data for your insurance or account matters (for example matters relating to the servicing and administration of your insurance policy or your investment account), this will affect our ability to provide you with the products and services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim. In this regard, it may mean that we will not be able to continue with your existing relationship with us and/or the contract you have with us will have to be terminated .This may be disadvantageous to you, as you may sustain a loss, losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.

6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Aviva to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data if you did not update us of the changes in your personal data.

6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties due to factors beyond our control.

6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

7. COMPLAINT PROCESS

7.1 If you have any complaint or feedback about how we are handling your personal data or complying with the PDPA, please contact our Data Protection Officers at: 

Individual Life and Health Insurance, MINDEF & MHA schemes
Tel: +65 6827 9933
Email: cs_life@aviva-asia.com

General Insurance
Tel: +65 6827 9966
Email: personal_insurance@aviva.com.sg

Group Insurance
Email: ebh_enquiries@aviva-asia.com

Navigator
Tel: +65 6827 7555
Email: service@navigator-asia.com

Office address
4 Shenton Way, #01-01 SGX Centre 2 Singapore 068807 

Operating hours
8.45am to 5.30pm, Mondays to Fridays, excluding Public Holidays.

7.2 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

7.3 We will certainly strive to attend to any complaint or grievance that you may have speedily and fairly.

8. UPDATES ON DATA PROTECTION POLICY

8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.aviva.com.sg/en/pdpa/

8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Last updated on 28 December 2017

Collection, Use and Disclosure

The Personal Data Protection Act

The Personal Data Protection Act or “PDPA” governs the collection, use and disclosure of personal data by private organisations. It contains various obligations relating to the Do-Not-Call Registry (“DNC Obligations”) and the protection of personal data (“DP Obligations”). The DNC Obligations came into force on 2 January 2014 while the DP Obligations came into force on 2 July 2014.

Useful Links

If you are an individual and you apply for or are holding an insurance policy or an investment account with Aviva Ltd or Navigator Investment Services Limited (collectively referred as “Aviva”), your personal data will be collected, used and/or disclosed in the course of your dealing with Aviva. Please follow this link for more information on how your personal data is/will be used. If you have an ElderShield and/or ElderShield supplement policy with us, please follow this Eldershield and/or ElderShield supplement link instead.

If you are a corporation and you request for or have a group insurance policy with Aviva, you may be collecting and passing individual’s personal data to/from Aviva. Please follow this link to see your obligations in relating to handling of personal data with Aviva.

If you have a MINDEF or MHA insurance policy with Aviva, your personal data will be collected, used and/or disclosed in the course of your dealing with Aviva. Please follow this link for more information on how your personal data is/will be used.

 

PURPOSES OF USE OF PERSONAL DATA

Marketing

If you consent to marketing, Aviva may contact you to inform you about Aviva or Aviva related company products or services, special offers or other information which may be of interest to you.

You can change your mind on the consent anytime. If you subsequently decide that you do not wish to receive marketing materials from us, all you need to do is to contact us.

Alternatively, if you decide that you would like to receive the above marketing materials, you can also contact us to do so.

Administration and Servicing

In order to carry out our business, process, administer and/or manage your relationship, cover, policy and/or account with Aviva Ltd or Navigator Investment Services Limited (collectively referred as “Aviva”), we will have to collect, use and disclose your personal data.

1. Personal Data
Such personal data may include information or data provided by you or other parties in the application forms, other forms or from other sources, including existing data in our record and/or to be collected in the future.

2. Purposes
Such personal data will be collected, used, disclosed and/or processed by Aviva (or Aviva group of companies) for the purpose(s) of:

(a) providing financial advice to recommend product(s) based on your financial needs analysis, where applicable;

(b) administration of your policy, which may include but is not limited to:

(i)    underwriting of the risk proposed
(ii)   requesting and collecting premiums
(iii)  providing regular information about your policy
(iv)  making changes or updates to your policy
(v)   reviewing or renewing or reinstating your policy
(vi)  carrying out your instructions or responding to any enquiries by you
(vii) assessing and processing your claim(s) made under the policy

(c) administration of your account which may include but is not limited to:

(i) maintenance of your account
(ii) performing or updating transactions on your account
(iii) carrying out your instructions or responding to any enquiries by you

(d) dealing in any matters relating to your policies and/or accounts (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages);

(e) managing your relationship with Aviva;

(f) compiling statistics or conducting research for company or industry exercises and studies, to design, review or improve our products and services;

(g) compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by Aviva and/or the industry;

(h) complying with applicable laws, regulations, rules, guidelines, schemes or directions imposed by any regulator, government body, statutory body, law enforcement agency or dispute resolution body;

(i) providing general information on product enhancements and services, which are relevant to your needs or policies (including increasing benefits, adding riders/supplements and/or insured lives);

(j) investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned; and

(k) archiving, backing-up or destroying personal data.

Some of these purposes may apply or continue to apply after your relationship, policy and/or account with Aviva has ended or is no longer in force or active.

3. Disclosure
Such personal data of yours will be disclosed by:

(a) Aviva to Aviva group of companies (whether in Singapore or elsewhere in the world where such Aviva group of companies are sited) and between each of them; and/or

(b) Aviva (or Aviva group of companies) to third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries, as and when relevant or necessary for the purposes as described above.

Without limiting the generality of the foregoing, Aviva may also disclose such personal data of yours to the following parties for the following purposes:

(i) To medical organisations, insurance offices or organisations, reinsurers, credit agencies, dispute resolution bodies or investigators for underwriting, claims, reinsurance and compliance/audit purposes;

(ii) To your broker, financial adviser or representatives (including any new intermediary appointed by you or the company) to service and administer your plan or policy;

(iii) To related companies for the processing and administration of your plan or policy;

(iv) To banks, CPF agent banks, credit card companies, other financial institutions, CPF Board or third party contractors for payment, collection or refund of any monies due or payable or upon their valid request;

(v) To third party vendors engaged by Aviva to perform processes required for the administration of your policy or account (e.g. data entry, printing and despatch of documents, claims administration etc.), for data analytics or to perform processes required to send marketing material or messages to you, where applicable;

(vi) To related companies or third party vendors engaged by Aviva to store and maintain our data and documents (including storage for business recovery purposes);

(vii) To any regulatory, government and statutory body to comply with applicable laws or regulation or upon their valid request; and

(viii) To related company or regional office or head office to comply with company policies and procedures or upon their valid request.

Neither Aviva nor any of its officials shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to Aviva and/or any of its officials disclosing.

4. Consent
By applying for an insurance policy or an investment account with Aviva, you consent to Aviva and/or Aviva group of companies:

(a) collecting, using, disclosing and/or processing the personal data mentioned above for the purposes as described above; and

(b) transferring the personal data mentioned above to other Aviva group of companies, its third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries where such third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries are sited (whether in Singapore or outside of Singapore), for the purposes as described above.

5. Consequence of withdrawing consent to the collection, use and disclosure of personal data for administration and servicing

You may withdraw your consent for Aviva to collect, use or disclose your personal data by giving Aviva reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so. For example, you may withdraw your consent for your personal data to be used for marketing purposes. This withdrawal will not affect Aviva’s ability to provide you with the products and services that you asked for or have with Aviva. 

However, if you withdraw your consent for Aviva to collect, use or disclose your personal data, Aviva will be unable to process, administer and/or manage your relationship, policy and/or account with us. To proceed with such withdrawal, you will be required to surrender or terminate all your policies or accounts with Aviva. This may be disadvantageous to you, as you may be losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.

                       

                       

 

 

PERSONAL DATA PROTECTION COMPLIANCE UNDERTAKINGS (BY CORPORATE PROSPECT/POLICYHOLDER)

1. The Company hereby represents, undertakes and warrants to Aviva Ltd (“Aviva”) that:

(a) for any personal data of individuals that the Company will be or is disclosing to Aviva, whether directly or through an intermediary, that the Company would have prior to disclosing such personal data to Aviva obtained the appropriate consent from the individuals whose personal data are being disclosed, to:

(i) permit the Company to collect, use and/or disclose the individuals’ personal data to Aviva for the purpose of issuance and administration of the Company’s insurance policy(ies) and/or account(s) with Aviva, including the processing of the individuals’ personal data for underwriting purposes, payment of premiums and/or claims purposes, and for statistical, compliance, audit and regulatory purposes;

(ii) permit Aviva and Aviva group of companies (in Singapore and/or elsewhere) to collect, use, disclose and/or process the individuals’ personal data for the purpose of issuance and administration of the Company’s insurance policy(ies) or such other policy(ies) and/or account(s) with Aviva, including but not limited to the processing of the individuals’ personal data for underwriting purposes, payment of premiums and/or claims purposes, and for statistical, compliance, audit and regulatory purposes; and

(iii) permit Aviva to disclose the individuals’ personal data to Aviva group of companies, third party service providers, suppliers, reinsurers or intermediaries, whether located in Singapore and/or elsewhere, for the purposes as described above;

(b) any personal data of individuals that the Company will be or is disclosing to Aviva are accurate. Further, the Company shall give Aviva notice in writing as soon as reasonably practicable should it be aware that any such personal data has been updated and/or changed after such disclosure;

(c) it shall give Aviva notice in writing as soon as reasonably practicable should it be aware that any individual above has withdrawn such consent as set out at sub-clause (a); and

(d) it shall otherwise assist Aviva to comply with the Personal Data Protection Act 2012 and all subsidiary legislation related thereto.

2. Notwithstanding anything to the contrary, the Company undertakes to indemnify and at all times hereafter to keep Aviva and Aviva group of companies (together with their respective officers, employees and agents) (each an “Injured Party”) indemnified against any and all losses, damages, actions, proceedings, costs, claims, demands, liabilities (including full legal costs on a solicitor and own client basis) which may be suffered or incurred by the Injured Party or asserted against the Injured Party by any person or entity (including Company, his/her agents) whatsoever, in respect of any matter or event whatsoever arising out of, in the course of, by reason of or in respect of:

(a) any breach of any of the provisions in this clause; and/or

(b) any action or omission by the Company, that causes Aviva and/or any of Aviva group of companies to be in breach of the PDPA.

PURPOSES OF USE OF PERSONAL DATA (FOR MINDEF/MHA POLICYHOLDERS)

Marketing

If you consent to marketing, Aviva may contact you to inform you about Aviva or Aviva related company products or services, special offers or other information which may be of interest to you.

You can change your mind on the consent anytime. If you subsequently decide that you do not wish to receive marketing materials from us, all you need to do is to contact us.

Alternatively, if you decide that you would like to receive the above marketing materials, you can also contact us to do so.

Personal Data Protection

In order to carry out our business, process, administer and/or manage your relationship, cover, policy and/or account with Aviva Ltd or Navigator Investment Services Limited (collectively referred as “Aviva”), we will have to collect, use and disclose your personal data.

1. Personal Data
Such personal data may include information or data provided by you or other parties in the application forms, other forms or from other sources, including existing data in our record and/or to be collected in the future.

2. Purposes
Such personal data will be collected, used, disclosed and/or processed by Aviva (or Aviva group of companies) for the purpose(s) of:

(a) providing financial advice to recommend product(s) based on your financial needs analysis, where applicable;

(b) administration of your policy, which may include but is not limited to:

(i)    underwriting of the risk proposed
(ii)   requesting and collecting premiums
(iii)  providing regular information about your policy
(iv)  making changes or updates to your policy
(v)   reviewing or renewing or reinstating your policy
(vi)  carrying out your instructions or responding to any enquiries by you
(vii) assessing and processing your claim(s) made under the policy

(c) administration of your account which may include but is not limited to:

(i) maintenance of your account
(ii) performing or updating transactions on your account
(iii) carrying out your instructions or responding to any enquiries by you

(d) dealing in any matters relating to your policies and/or accounts (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages);

(e) managing your relationship with Aviva;

(f) enrolling you and/or proposed insured lives in membership, promotional, discount or rewards programs relating to the policy;

(g) compiling statistics or conducting research for company or industry exercises and studies, to design, review or improve our products and services;

(h) compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by Aviva and/or the industry;

(i) complying with applicable laws, regulations, rules, guidelines, schemes or directions imposed by any regulator, government body, statutory body, law enforcement agency or dispute resolution body;

(j) providing general information on product enhancements and services, which are relevant to your needs or policies (including increasing benefits, adding riders/supplements and/or insured lives);

(k) investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned; and

(l) archiving, backing-up or destroying personal data.

Some of these purposes may apply or continue to apply after your relationship, policy and/or account with Aviva has ended or is no longer in force or active.

3. Disclosure
Such personal data of yours will be disclosed by:

(a) Aviva to Aviva group of companies (whether in Singapore or elsewhere in the world where such Aviva group of companies are sited) and between each of them; and/or

(b) Aviva (or Aviva group of companies) to third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries, as and when relevant or necessary for the purposes as described above.

Without limiting the generality of the foregoing, Aviva may also disclose such personal data of yours to the following parties for the following purposes:

(i) To medical organisations, insurance offices or organisations, reinsurers, credit agencies, dispute resolution bodies or investigators for underwriting, claims, reinsurance and compliance/audit purposes;

(ii) To your broker, financial adviser or representatives (including any new intermediary appointed by you or the company) to service and administer your plan or policy;

(iii) To related companies for the processing and administration of your plan or policy;

(iv) To banks, CPF agent banks, credit card companies, other financial institutions, CPF Board or third party contractors for payment, collection or refund of any monies due or payable or upon their valid request;

(v) To third party vendors engaged by Aviva to perform processes required for the administration of your policy or account (e.g. data entry, printing and despatch of documents, claims administration etc.), for data analytics or to perform processes required to send marketing material or messages to you, where applicable;

(vi) To related companies or third party vendors engaged by Aviva to store and maintain our data and documents (including storage for business recovery purposes);

(vii) To any regulatory, government and statutory body to comply with applicable laws or regulation or upon their valid request;

(viii) To related company or regional office or head office to comply with company policies and procedures or upon their valid request; and

(ix) To Ministry of Defense or Ministry of Home Affairs (“Authority”) as may be applicable or such other insurance entity selected by the Authority for the purpose of facilitating and/or administering insurance coverage with the insurance entity. 

Neither Aviva nor any of its officials shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to Aviva and/or any of its officials disclosing.

4. Consent
By applying for an insurance policy or an investment account with Aviva, you consent to Aviva and/or Aviva group of companies:

(a) collecting, using, disclosing and/or processing the personal data mentioned above for the purposes as described above; and

(b) transferring the personal data mentioned above to other Aviva group of companies, its third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries where such third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries are sited (whether in Singapore or outside of Singapore), for the purposes as described above.

5. Consequence of withdrawing consent to the collection, use and disclosure of personal data for administration and servicing

You may withdraw your consent for Aviva to collect, use or disclose your personal data by giving Aviva reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so. For example, you may withdraw your consent for your personal data to be used for marketing purposes. This withdrawal will not affect Aviva’s ability to provide you with the products and services that you asked for or have with Aviva. 

However, if you withdraw your consent for Aviva to collect, use or disclose your personal data, Aviva will be unable to process, administer and/or manage your relationship, policy and/or account with us. To proceed with such withdrawal, you will be required to surrender or terminate all your policies or accounts with Aviva. This may be disadvantageous to you, as you may be losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.

Contact Information

If you have any queries on our personal data protection policies, you may refer to the Frequently Asked Questions or contact us as follows:

Our operating hours are from 8.45am to 5.30pm, Monday to Friday, excluding public holidays.

Frequently Asked Questions

For general information on Data Protection and DNC Registry, please visit the PDPC website

If you are unable to find the information you are seeking, the PDPC website also has a comprehensive FAQ for individuals. Alternatively, you may also contact us through our Customer Hotlines.

General

How does the Personal Data Protection Act 2012 (PDPA) affect me as an individual?

The PDPA governs the collection, use, disclosure and care of personal data. It recognises your rights to protect your personal data, including rights of access and correction. It also acknowledges the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

The PDPA also provides for the creation of a Do Not Call (DNC) Registry. The DNC Registry allows individuals to register their Singapore telephone numbers to opt out of receiving marketing messages through phone calls, text messages such as SMS or MMS, and/or faxes from organisations.

When did the Personal Data Protection Act (PDPA) come into force?

The PDPA provisions relating to the DNC Registry came into effect on 2 January 2014 and the provisions relating to data protection came into force on 2 July 2014.

You can read more from the Personal Data Protection Commission website.

How will my personal data be managed in accordance with PDPA requirements?

As an organisation, we are required to comply with the PDPA. Accordingly, we have developed and will continue to update our policies and practices to meet the obligations required under the PDPA.

An overview of our policies and practices is available on our Overview page.

I would like to know more about PDPA. Can I speak to someone from Aviva directly?

You may contact us through our Customer Hotlines.

Data Protection

I would like to allow Aviva to contact me for marketing purposes – how can I do that?

You can register your consent for marketing purposes with Aviva by contacting us through our Customer Hotlines.

I don’t remember whether I have given consent for marketing purposes to Aviva – how can I check?

To check if you have previously given consent for marketing purposes to Aviva, you can contact us through our Customer Hotlines.

I want to only receive selected messages, via specific channels. Can Aviva do that for me?

You can choose whether or not to receive marketing messages and specify the channels to receive them by. To do so, please contact us through our Customer Hotlines.

Please note that even if you choose not to receive all marketing messages, you will still receive communications relating to follow up, servicing and other updates pertaining to your application or policy/account with Aviva.

How can I update my consent and personal details with Aviva?

You can update your consent and personal details through our Customer Hotlines.

Can I withdraw my consent for the use of my personal details with Aviva?

You may withdraw your consent for us to collect, use or disclose your personal data by giving us reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so.

For example, you may withdraw your consent for your personal data to be used for marketing purposes. This withdrawal will not affect our ability to provide you with the products and services that you asked for or have with us.

But if you withdraw your consent for us to use your personal data for your insurance matters (matters relating to the servicing and administration of your insurance policy), this will affect our ability to provide you with the products and services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim. Withdrawing such consent may result in the termination of all your policies with us. This may be disadvantageous to you, as you may lose valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.

You may contact us through our Customer Hotlines to request for withdrawal of consent and/or to discuss the various options available to help you achieve your intention.

Can I request access to my personal data held by Aviva? How do I do so? Is there a fee?

You can request for access to your personal data through our Customer Hotlines.

For your convenience, we offer a standard access statement free of charge. This statement provides basic information on your personal data as well as generic information on how your personal data has been or may have been used or disclosed by us within a year from your request.

For detailed access to additional or specific information, you may make the request through our Customer Hotlines. A fee will be charged according to the amount and complexity of the additional information request. We will prepare the additional information after you confirm your request and make payment for the fee.

Request for access will be provided within 30 days. If we are not able to provide you with the requested access within the 30 days, we will update you on the revised date before the end of the 30 days.

In certain situations, we will not accede to the request for access. You may refer to the section 21(3) and the Fifth Schedule of the PDPA for the list of these situations.

An example would be the situation where your request relates to a policy for which you are not the policyholder and the policyholder does not consent to the disclosure of his identity. In this case, we will not provide you the personal data or other information if doing so could reasonably be expected to reveal the personal data of the policyholder.

If you are requesting for your personal data in relation to an Employee Benefits policy under which you are an insured person, we encourage you to approach your employer for this request.

Can I request to correct my personal data held by Aviva? How do I do so? Is there a fee?

You can request for correction of your personal data through our Customer Hotlines.

If you consent, we will send the corrected personal data only to specific organisations to whom we had disclosed such personal data to within the past 1 year.

To facilitate the prompt processing for a request for correction, you are encouraged to obtain the concurrence of the policyholder (i.e. the party who owns the policy or account with Aviva) before you make a request for a correction of personal data under a policy which you do not own.

We do not charge a fee for correction of personal data.

Do Not Call Registry

How does this Registry affect me?

You may register your Singapore telephone number(s) with the DNC Registry to opt out of receiving marketing messages through telephone calls, text messages and/or faxes. This allows you to have control over the types of messages you receive on your telephone, mobile phone, or fax machine.

However, you can still choose to receive telemarketing messages from selected organisations by providing them with your clear and unambiguous consent in written or other retrievable form. For those organisations that you have granted your consent, they will be able to send telemarketing messages to you even if your Singapore telephone number is registered with the DNC Registry.

If you subsequently change your mind, you can still withdraw your consent for telemarketing messages from the respective organisation.

How can I register, de-register or check my registration for Do Not Call?

You may register, de-register or check the registration status of your Singapore telephone numbers on the DNC Registry set up by the PDPC at www.dnc.gov.sg.

If you had previously given consent to receive telemarketing messages from Aviva but have changed your mind, you can update your consent through our Customer Hotlines.

If you had previously not given consent to receive telemarketing messages from Aviva but would like to do so, you can also update your consent through our Customer Hotlines

If I have registered with the DNC Registry, do I need to register with Aviva?

No. As long as you have not given clear and unambiguous consent for telemarketing to Aviva, Aviva will not send any telemarketing messages to you. 

Will Aviva contact me with telemarketing messages if I have registered with the DNC Registry?

If you have previously consented to receiving telemarketing messages from Aviva, we may contact you with telemarketing messages even though you have registered with the DNC Registry.

However, if you had previously informed us that you do not wish to receive telemarketing messages from Aviva, we will not send you any telemarketing messages. You may change your consent for telemarketing at any time. To do so, please contact us through our Customer Hotlines.

Regardless of your registration with the DNC Registry, you may still receive calls and messages for follow up, servicing and other updates pertaining to your policy or account with Aviva.

I don’t want to receive marketing calls, but I am ok to receive SMSes – does this affect me?

For the DNC Registry, you can register your Singapore telephone number for any or all of the three DNC Registers, based on your preferences.

The registers are:

  • No Voice Call Register
  • No Text Message Register
  • No Fax Message Register

The DNC Registry is only for Singapore telephone numbers and it does not include mail and e-mail communications. 

If you do not wish to receive any marketing messages via mail or email, you can inform us and we will update your preference in our company records. You will then no longer receive any mails or emails for marketing messages.

However, you may still receive various communications relating to follow up, servicing and other updates pertaining to your application or policy/account with Aviva.

I gave consent to Aviva to send marketing communications to me by call and message on my telephone number. Subsequently, I registered this Singapore telephone number with the DNC Registry. What does this mean for me?

As you have provided the consent to Aviva earlier, it still allows Aviva to send you marketing materials regardless of your DNC registration. 

But if you change your mind, you may withdraw your consent for marketing messages through our Customer Hotlines. We will update your request within 3 business days. You can expect not to receive telemarketing messages 30 days after making your request. 

Can I register more than one contact number for Do Not Call?

Yes, you can register one or more of your Singapore telephone numbers with the DNC Registry. 

Can I specify which type of telemarketing messages that can be sent to me and/or for only certain product types?

For telemarketing messages sent by Aviva, there is no option for selection based on specific product types.

However, you may select your preferences to receive telemarketing messages via telephone call or text message. In addition, you may also choose to receive marketing messages via mail or email. You may effect this by contacting us through our Customer Hotlines.

What is a telemarketing message?

A telemarketing message is a message that is sent to your Singapore telephone number to promote or advertise a product or service and/or their provider or supplier. The DNC Registry’s focus is on telemarketing calls or messages of a commercial nature sent to consumers.

It does not include:

  • Servicing and other updates pertaining to products and services you have applied for or purchased;
  • Messages for pure market survey or market research;
  • Personal messages sent by individuals; or
  • Telemarketing calls or messages of a commercial nature that target other businesses.

For the full list of messages that are excluded under the PDPA, please refer to the Eighth Schedule of the PDPA

What’s the turnaround time to register my request to be in the Do Not Call list or to remove from the list?

Your registration or de-registration with the DNC Registry is immediate.

However, when a company checks the DNC Registry to see if your telephone number is registered, they are allowed a validity period of 30 days to contact you. Hence, you may continue to receive telemarketing messages for up to 30 days after registering with the DNC Registry.

If you had previously given consent to receive telemarketing messages to specific organisations, these organisations can continue to send you telemarketing messages even though you have registered your request with the DNC Registry.

If you have changed your mind about receiving marketing messages from Aviva, you can update your consent through our Customer Hotlines. We will update your withdrawal of consent within 3 business days. You can expect not to receive telemarketing messages 30 days after making your request.

If I have changed my mobile number, do I need to re-register again for Do Not Call?

For the DNC Registry, registration is by telephone number and you will need to register your new mobile number if you wish to continue to be on the DNC Register(s).

If you had previously withdrawn consent to receive telemarketing messages from Aviva, there is no need to register your new telephone number with us for the purpose of not receiving telemarketing messages. However, we do encourage you to register your new contact with us so that we can contact you for matters relating to the servicing of your policy, when required. 

I have already registered myself with the DNC Registry but I am still receiving telemarketing messages from Aviva.

There are certain scenarios why you may still be receiving telemarketing messages after you have registered yourself with the DNC Registry.

You may still continue to receive telemarketing messages for up to 30 days after registering with the DNC Registry. This is because when a company checks the DNC Registry to see if your telephone number is registered, they are allowed a validity period of 30 days to contact you. Hence, you may continue to receive telemarketing messages during this interim period.

In addition, if you have previously provided clear and unambiguous consent for Aviva to contact you for telemarketing messages, Aviva can still contact you even though you have registered your number with the DNC Registry.

If you have an incident that you would like us to check on, please contact us through our Customer Hotlines

Can I choose to withdraw consent for telemarketing on only one of several numbers I have with Aviva?

No, if you had withdrawn your consent for telemarketing with Aviva, we will not call or send you telemarketing messages on all telephone numbers listed under your name.

If you have not given clear and unambiguous consent for Aviva to send telemarketing messages to you, you can achieve the same result by registering the one number with the DNC Registry via their website www.dnc.gov.sg