Does the Personal Data Protection Act ("PDPA") allow regulated dealers to ask customers for their particulars?
The data protection provisions in the PDPA does not prohibit the collection, use or disclosure of personal data (including NRIC number) as long as it is required for compliance with the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act ("PSPM Act") and Regulations.
However, regulated dealers are required to ensure that reasonable security arrangements are in place to protect personal data in their possession or under their control.
Other than for purposes of compliance with the Act and Regulations, the personal information obtained cannot be used or disclosed for other purposes (e.g. marketing) without the consent of the individual.
For guidance on how personal information should be obtained, handled and stored, you may wish to refer to the Personal Data Protection Commission's website at https://www.pdpc.gov.sg/.
Related questions
I am unable to obtain all the identity of the individuals with senior management position of my corporate customer. Can I just proceed to transact with the corporate customer by obtaining and verifying the ACRA BizFile report only? What if customer refuses to provide his identifying information for customer due diligence?
Who needs to register as a regulated dealer?
I am a foreign incorporated business/ company/ individual. Do I need to register (e.g. I am the supplier of precious stones and precious metals to a regulated dealer in Singapore. I do not carry out sales in Singapore)?
As a precious stones and precious metals dealer, are there individuals and entities that I am prohibited from dealing with? Where can I find the relevant information / lists of such individuals and entities?
