Other local requirements
Are there any other key local requirements?
Apart from compliance with applicable gambling legislation as set out in the foregoing responses, there are generally no key local requirements for the operation of prize promotions per se. However, it would be prudent for organizations that run prize promotions to be aware of Singapore data protection laws which they are likely to be bound by. In this regard, such organizations must observe and comply with the requirements under the PDPA when collecting data for the purpose of administering and managing any prize draws, competitions, promotional offers and other marketing activities.
The PDPA governs the collection, use and disclosure of personal data by all private organizations. Promoters must:
- Inform participants on the purposes for collection, use and disclosure of their personal data on or before collecting the personal data;
- Ensure that consent has been obtained from participants before collecting, using or disclosure of the personal data; and
- Keep personal data in their possession secure from unauthorized access, modification, disclosure, use, collection or copying (either in hardcopy or electronic form).
As a general rule, organizations may wish to note that they should avoid collecting, retaining or disclosing more personal data than is necessary to fulfil the relevant purpose. Further, it should be noted that due to the issuance of Advisory Guidelines on the PDPA for National Registration Identity Card ('NRIC') and Other National Identification Numbers by the Personal Data Protection Commission on 31 August 2018, organisations will be prohibited from collecting, using or disclosing NRIC numbers, or making copies of identity cards of their customers or potential customers, from 1 September 2019. Those that have collected NRIC numbers or other identity card numbers are encouraged to assess if they need to retain these numbers, and if not, are suggested to dispose of them responsibly and in compliance with the PDPA.
Additionally, organizations operating prize promotions may also be bound by local consumer protection laws, such as the Unfair Contract Terms Act.