Propnex Ltd. · SGX:OYY
Propnex — Investor Presentation (July 2014)
50 slides from Propnex's investor presentation, July 2014
Slide 1: What YOU should know about PDPA…
What YOU should know about PDPA… B E F O R E & A F TE R 2 N D J U LY 2014
Slide 2: Disclaimer
DISCLAIMER Whilst every effort has been made to ensure that the information provided is correct and up-to-date, no warranty is given that it is free from error or omission. It should also be noted that the information given is of a general nature and may not be applicable in a specific situation. Ac
Slide 3: Personal Data Protection Act: Existing personal data under your care
Personal Data Protection Act (PDPA) Existing personal data under your care • According to the PDPA, an organisation may continue to use personal data that has been collected before the data protection provisions of the PDPA come into effect on 2 July 2014 for the purposes for which the personal data
Slide 4: Personal Data Protection Act: What this means to you
Personal Data Protection Act (PDPA) What this means to you This is applicable, especially in the context of prospecting and marketing campaigns, and applies even to email & printed mail as long as personal data is being used. Before 2nd July 2014 You can continue to send email/printed mail to existi
Slide 5: FAQ: What is the definition of existing data?
FAQ: What is the definition of existing data? If the contact list/database was obtained from 3rd party before 2 July, but agent has not been contacting the prospect, can they still perform direct/email telemarketing? Or the existing data requires the proof of former communication for justification?
Slide 6: FAQ: Existing personal data collected before 2 July 2014
FAQ: What can an organisation do with respect to existing personal data collected before the effective date of the data protection rules on 2 July 2014? • Generally an RES/Organisation can continue to use the personal data that was collected prior to the effective date of the data protection rules,
Slide 7: FAQ: How can an organisation obtain consent?
FAQ: How can an organisation obtain an individual’s consent for the collection, use or disclosure of his or her personal data? • Consent can be obtained in a number of different ways. As a best practice, an organisation should obtain consent that is in writing or recorded in a manner that is accessi
Slide 8: FAQ: Is failure to opt out a form of consent?
FAQ: Is the failure to opt out a form of consent? • Deeming that an individual has given his consent through inaction on his/her part will not be regarded as consent in all situations. • Whether or not a failure to opt out can be regarded as consent will depend on the actual circumstances and facts
Slide 9: FAQ: Selling databases containing personal data
FAQ: Can an organisation selling databases containing personal data to other organisations continue to do so after the PDPA comes into effect? • An organisation may use personal data collected before 2 July 2014 for the purposes for which the personal data was collected, unless consent for such use
Slide 10: Prospecting: Telemarketing
Prospecting TELEMARKETING
Slide 11: Telemarketing messages and DNC requirements
Messa ges. not puniions | Be Pron telemarketing ‘ Ferret cit employment opportunities; messages * Warranty information, product recall information, and safety or security under the i information relating to a product you have purchased; R ts * Delivery of goods or services, including relevant produc
Slide 12: Consent Telemarketing Flow — PDPA & DNC Registry
CONSENT Telemarketing Flow — PDPA & DNC Registry (aster July 2, 2014) Notify Data Protection Officer Telemarketing ts contact from public available OR Existing amas Isthereclear& Check 30 day unambiguous validity consent data before sae Is there eS ae consent Is Consent pice Ge from list valid? Spid
Slide 13: Telemarketing Workflow Process
Telemarketing Workflow Process 1. Is there consent from the list source? 2. Is there clear and unambiguous consent? 3. Is it within 30days validity period? If any of the above is a “No” answer, please END or REMOVE contact before proceeding
Slide 14: Telemarketing Workflow Process: Notifying the DPO
Telemarketing Workflow Process 1. Notify Propnex data protection officer via email DPO@propnex.com 2. Agent to inform DPO if there is a withdrawal of consent from their database 3. DPO update the withdrawal of consent into company blacklist (opt out list) database
Slide 15: Telemarketing Workflow Process: Recommendation
Telemarketing Workflow Process Suggestion/Recommendation If there is no consent given to contact an individual (e.g from a 3rd party list provider), the call or SMS should end (if personal data is collected after July 2). There is no reason to go on checking the DNC registry since there is no opt-
Slide 16: Propnex PDPA policies
Telemarketing Workflow Process Propnex PDPA policies The company will not recognize and will not support the following: • Pre-scrubbed lists from third party vendors • Applications or any third party that claim to check DNC registry on your behalf
Slide 17: Telemarketing Employment Form
Telemarketing Employment Form 1. For new telemarketer, please download the “Telemarketer Employment Form” at Propnex Virtual office -> Services- >Downloadable forms->PDPA 2. The forms can be downloaded at Propnex Virtual office -> Services->Downloadable forms->PDPA
Slide 18: Addendum to Employment Agreement (Existing Staff)
PROPNEX-Addendum to Employment Agreement (EXISTING STAFF) 1. For existing telemarketers, please ensure that the telemarketers sign the document titled “PROPNEX-Addendum to Employment Agreement (EXISTING STAFF)” (5 pages) 2. The forms can be downloaded at Propnex Virtual office -> Services->Downloada
Slide 19: FAQ: Consent from individual registered with DNC
FAQ: If an RES/organisation has obtained consent from an individual who is registered with the DNC Registry, can the RES/organisation send telemarketing messages to him or her? • An RES/organisation that has been given clear and unambiguous consent by the individual, in written or other accessible f
Slide 20: Calling through Company Landlines
Calling through Company (Propnex) Landlines • The company has designated certain lines that can only be used to make telemarketing calls. These lines have been installed with SpiderGate, where outgoing calls will automatically be blocked if the destination number is either in the company’s blacklist
Slide 21: Calling from Home
Calling from Home • When making calls from a home landline, employees and associates are expected to practice the due diligence of checking the respective destination telephones against the DNC registry. • Note that the company does not provide any specific tool for use on your home telephone. • It
Slide 22: Calls and SMS through outsourced telemarketing services
Calls / Sending SMS made through telemarketing agencies / outsourced services • In the event that an individual has outsourced his / her telemarketing activities to a third party, note that individual is personally liable for what the external party does. In the case of a breach, the PDPC will consi
Slide 23: Calling/Contacting a Number on the DNC
Calling/Contacting a Number on the DNC In the unlikely but possible scenarios where an: • Individual recently registered in the DNC registry (in the last 30 days after a previous check was made) • Individual thinks that he/she is registered in the DNC registry • ...do not be alarmed if an individual
Slide 24: Prospecting: E-mail Marketing
Prospecting E-MAIL MARKETING
Slide 25: Email Marketing Flow — PDPA & DNC Registry
Email Marketing Flow — PDPA & DNC Registry (atter July 2, 2014) Notify Data Protection Officer Marketing Isitan Has existing business contact in purpose database? changed? Seek fresh consent or END ie concece Is there wares from public consent Company’ s available from list blacklist? source? source
Slide 26: FAQ: Are emails and post covered under the DNC Registry?
FAQ: Are emails and mail delivered by post covered under the DNC Registry? The DNC Registry covers marketing messages sent to Singapore telephone numbers. Emails and mails delivered by post are not included within the scope of the DNC registry. Email Emails are not included within the scope of the D
Slide 27: FAQ: How is the PDPA different from the Spam Control Act?
FAQ: How is the PDPA different from the Spam Control Act? • The Spam Control Act (“SCA”) sets out a framework to manage unsolicited commercial electronic messages sent in bulk through electronic mail, text and multimedia messaging, otherwise known as "spam". The SCA requires organisations to, among
Slide 28: Importance of “Unsub” for your Outgoing Campaigns
Importance of “Unsub” for your Outgoing Campaigns All RES are reminded to check Propnex blacklist (opt-out) list before conducting any outgoing marketing campaigns. You should consult two categories of blacklist which will be updated regularly: 1) Telemarketing Blacklist (SpiderGate users need not d
Slide 29: Importance of “Unsub”: Handling opt-out requests
Importance of “Unsub” for your Outgoing Campaigns • The company takes all requests for opt-outs and “unsubs” very seriously as these are considered withdrawal of consent. • Should any of the above requests be made, individuals are expected to process the request immediately and ensure that the respe
Slide 30: Company blacklist (Opt out list)
Company blacklist (Opt out list) LATEST DO-NOT CALL LIST (AS AT 1 JULY 2014)
Slide 31: Company blacklist (Opt out list)
Company blacklist (Opt out list) LATEST DO-NOT CALL LIST (AS AT 1 JULY 2014)
Slide 32: Company blacklist (Opt out list)
Company blacklist (Opt out list) “Contact” contains company opt out number where agents are not supposed to call “Email Address” contains company opt out email address where agents are not supposed to call
Slide 33: Prospecting: Direct Marketing
Prospecting DIRECT MARKETING
Slide 34: Direct Marketing Flow — PDPA & DNC Registry
Direct Marketing Flow — PDPA & DNC Registry (after july 2, 2014) or opt- t) m date Notify Data Direct Marketing Protection Officer business purpose changed? Seek fresh Is contact Is there consent or END from public consent available from ist 2? source? Existing source? data before Isitin July 2? Com
Slide 35: Direct Marketing Workflow Process
Direct Marketing Workflow Process Suggestion/Recommendation If you are sending direct mailer, use generic name such as to the “Owner” or “Resident”. If you are using personal data such as the name of the owner and their mailing address, please do the following checks: 1) Is it an existing contac
Slide 36: Withdrawal of Consent
Withdrawal of Consent With the enforcement of the PDPA, individuals can now withdraw their consent at any time. Do note that "unsub" is considered a withdrawal of consent. Therefore, individuals can "unsub" to any of the following: Email Printed Mailers SMS / Calls /Faxes (if they are not on D
Slide 37: 9 main obligations of PDPA
9 main obligation of PDPA
Slide 38: Compliance with the new PDPA: Consent and Purpose Limitation
Compliance with the new PDPA enforced on 2 July 2014 1. Consent Obligation You can only collect, use or disclose personal data for purposes for which the individual has given his or her consent, especially when you are prospecting or running your demand generation activities. Ensure you use the cons
Slide 39: Compliance with the new PDPA: Access, Accuracy, Protection
Compliance with the new PDPA enforced on 2 July 2014 4. Access and Correction Obligation Upon request, you will need to share how you have been using or who you have disclosed personal data of an individual to in the past year before that request is made. Remember to keep the relevant records for fu
Slide 40: Compliance with the new PDPA: Retention, Transfer, Openness
Compliance with the new PDPA enforced on 2 July 2014 7. Retention Limitation Obligation You should cease retention of personal data or remove the means by which the personal data can be associated with particular individuals when it is no longer necessary for any business or legal purpose. You shoul
Slide 41: 9 Obligations of PDPA: Consequences of non-compliance
9 Obligations of PDPA If you do not comply with the 9 obligations… ...You can be fined up to $1m in financial penalties & also be sued If you don't ask for consent at the time of … You will lose the trust of your clients collection… If you use personal data beyond the purpose you …You are using pers
Slide 42: Recommendation
Recommendation
Slide 43: 2 methods that Propnex will support
2 methods that Propnex will support The Company only recognizes two methods for staff and associates to be checking against the company and National DNC. Method 1: Official Checks with the Internet website of PDPC at http://www.dnc.gov.sg Method 2: Checks through SpiderGate (From Straits Interac
Slide 44: Method 1: Official Checks with www.DNC.gov.sg
2 methods that Propnex will support Method 1: Official Checks with www.DNC.gov.sg Remember to • Check on every outbound call and SMS - When checking, indicate all checks as "checking on behalf" & list our estate agency's name • Keep evidence of checking with DNC. • Keep in mind the different validit
Slide 45: Method 2: Using SpiderGate
2 methods that Propnex will support Method 2: Using SpiderGate The company has signed a professional contract with Straits Interactive to deploy the SpiderGate DNC Management System within its workforce in both the company’s fixed landlines, on smart mobile phones as well as for the purpose of SMS b
Slide 46: Keeping Records of Compliance
Keeping Records of Compliance All individuals, who have a DNC account, are expected to keep their own records or logs of calls, text messages, and faxes as well as the respective validity dates of DNC checks made for future reference - should there be a complaint or an investigation. For SpiderGate
Slide 47: Get Clear & Unambiguous Consent
Get Clear & Unambiguous Consent As a best practice, all associates should make a conscious effort to get “clear & unambiguous” consent from your prospects or referrals so that you need not check with the DNC Registry. This means that you will need to keep detailed records if your prospects specific
Slide 48: Get Clear & Unambiguous Consent: Penalties and records
Get Clear & Unambiguous Consent Under no circumstances should you send an SMS to get consent, or ask for consent during a cold call. If you do so, you will be in breach of the DNC provisions and you will be subject to a fine of up to $10,000 per offence. All associates are expected to manage your
Slide 49: Conclusions
Conclusions Currently PDPA act cover only a generic areas and there will be dynamic situations which will be subjected to further clarifications based on Past Cases,Present Contexts and Circumstances
Slide 50: The Journey continues…
The Journey continues…