Singapore PDPA

WorkSAFE App — Privacy Policy

Last Updated: 7 July 2026

The purpose of this document (“Privacy Policy”) is to inform you how Strides Digital Pte. Ltd. (“Strides Digital”), the digital and technology arm of STRIDES, the commercial business arm of SMRT Corporation Ltd, manages Personal Data (as defined below) in connection with the WorkSAFE App (the web portal and mobile application, collectively the “App”) in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). Please take a moment to read this Privacy Policy so that you are aware of and understand the purposes for which we collect, use and disclose your Personal Data.

The App is a workplace safety and health (“WSH”) platform provided for use by employees, contractors, and authorised personnel of SMRT Corporation Ltd and its related corporations (collectively, the “Companies”). By accessing or using the App, submitting information to us, or otherwise interacting with us, you agree and consent to Strides Digital, the Companies, and our respective representatives and/or agents (“Representatives”) (collectively referred to herein as “we”, “us” or “our”) collecting, using, disclosing and sharing your Personal Data amongst ourselves, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us or the Companies in respect of your Personal Data (including any consents provided in the course of your employment or engagement), and your consents herein are cumulative and additional to any rights which we may have under applicable law to collect, use or disclose and/or otherwise process your Personal Data.

We may from time to time update this Privacy Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. We will notify you of material updates in any form we deem appropriate, including by posting a notice within the App or contacting you via the contact particulars in our records. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

1.1 In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

1.2 Examples of such Personal Data we may collect in connection with the App include (depending on the nature of your interaction with the App):

your name, NRIC/FIN or work pass details, employee or staff identification number, telephone number(s), email address, and organisational particulars (company, business unit, division, department, job title, and workplace safety appointments);
information retrieved from Myinfo with your consent when you sign in or onboard using Singpass (see Section 5);
the content of safety records you create or are named in — including incident and hazard reports, Gemba walk records, toolbox meeting records, stop-work orders, risk assessments, and witness or party details contained in them;
photographs, videos, documents, and other attachments you upload;
voice recordings you choose to make in the App and the text transcripts generated from them;
messages you exchange with the App’s AI safety assistant and feedback or issue reports you submit; and
technical data such as device type, operating system, app version, IP address, sign-in records, and usage logs.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

when your organisation provisions your account, or when you sign in using your corporate credentials (Microsoft Entra ID single sign-on), Singpass, Google, or email and password — including organisational particulars synchronised from your employer’s corporate directory;
when you submit any form or record within the App, including incident and hazard reports, Gemba walks, toolbox meetings, stop-work orders, risk assessments, and onboarding or declaration forms;
when you upload photographs, videos, or documents, or record audio using the App’s voice input features;
when you interact with the App’s AI safety assistant or use search, library, or insights features;
when you are named in, assigned to, or notified about a safety record created by another user (for example, as a witness, reporting officer, or person involved in an incident);
when you contact us or submit feedback, queries, or in-app issue reports;
when we receive your Personal Data from the Companies (as your employer or principal), business partners, public agencies, or other third parties in connection with your use of the App; and/or
when you submit your Personal Data to us for any other reason.

2.2 If you provide us with any Personal Data relating to a third party (e.g. details of witnesses, persons involved in an incident, or other workers), by submitting such information to us, you represent to us that you have obtained the consent of such third party, or are otherwise entitled under applicable law, to provide us with their Personal Data for the purposes set out in this Privacy Policy.

2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so on your part may result in our inability to provide you with access to the App or its features.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:

operating, administering and providing the App and its features, including authenticating your identity and managing your account, roles, and access rights;
recording, processing, routing, investigating and resolving workplace safety matters — including incident and hazard reports, Gemba walks, toolbox meetings, stop-work orders, and risk assessments — and notifying the relevant personnel of such matters;
supporting the Companies’ compliance with the Workplace Safety and Health Act 2006 and other applicable WSH laws, regulations, codes of practice and guidelines, including incident reporting obligations to relevant authorities;
transcribing voice recordings you choose to make, and processing content you submit, using AI services in order to provide features such as voice input, report pre-classification, guided form-filling, and the AI safety assistant (see Section 6);
generating safety statistics, dashboards, insights and reports for the Companies, including in aggregated or de-identified form;
responding to, processing and handling your complaints, queries, requests, feedback and suggestions, and providing user support;
managing the administrative, business and technical operations of Strides Digital and the Companies, and complying with internal policies and procedures;
verifying your identity and carrying out due diligence or security checks, including contractor onboarding;
sending you service communications relating to the App — such as notifications of safety matters assigned to you, status updates on reports you have made, account and security notices, and one-time passcodes — via in-app notification, email, SMS, or messaging platforms (e.g. WhatsApp);
preventing, detecting and investigating crime, fraud or misuse of the App, and managing the safety and security of the App and our systems (including audit logging and security testing);
conducting audits, reviews and analysis of our internal processes, and managing and preparing reports on incidents and accidents;
in connection with any claims, actions or proceedings (including obtaining legal advice and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies, and/or assisting with any enquiries, requests, or investigations by relevant authorities; and/or
any other purpose relating to or reasonably necessary for any of the above.

These purposes may continue to apply even after your employment or engagement with the Companies ends or you no longer use the App, to the extent reasonably necessary (for example, retention of incident records required by law).

3.2 In addition, depending on the nature of your relationship with us:

If you are an employee of the Companies: your organisational particulars (name, email, employee ID, company, division, department, job title) may be synchronised from your employer’s corporate directory to provision and maintain your account, determine your access rights and safety appointments, and route safety matters to the appropriate personnel;
If you are a contractor or external worker: we may collect and use your identity and work pass particulars (including via Singpass/Myinfo, see Section 5) to verify your identity, complete onboarding, and associate you with the correct employer, worksite, and safety records; and/or
If you are named in a safety record (for example as a witness or person involved in an incident): your particulars will be used for the investigation, resolution and reporting of that matter.

3.3 We do not use your Personal Data collected through the App for marketing purposes, and we do not sell your Personal Data. Communications you receive from the App are service communications necessary for its workplace safety function.

4. Disclosure of Personal Data

4.1 We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether located in Singapore or overseas:

SMRT Corporation Ltd and its related corporations, including your employer or principal within the Companies, and their authorised personnel (such as safety officers, supervisors, and administrators) on a need-to-know basis consistent with their role in the App;
agents, contractors or third-party service providers who provide services to us in connection with the App, such as cloud hosting and infrastructure, artificial intelligence and speech transcription services, email, SMS and messaging delivery, identity and authentication services, information technology, and professional support services;
relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas — including the Ministry of Manpower and the Land Transport Authority — to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them (including statutory incident reporting);
our professional advisers such as consultants, auditors and lawyers;
any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to mergers, acquisitions, debt or asset sales) involving Strides Digital or any of the Companies; and/or
any other party to whom you authorise us to disclose your Personal Data.

4.2 Your Personal Data is hosted on cloud infrastructure located in Singapore. Where any disclosure or processing involves a transfer of Personal Data outside Singapore, we will take steps to ensure that the recipient is bound by legally enforceable obligations to provide the transferred Personal Data a standard of protection at least comparable to that under the PDPA.

4.3 We may also share information in aggregate or anonymised form (such as aggregated safety statistics) with the abovementioned parties.

5. Singpass and Myinfo

5.1 If you choose to sign in or onboard using Singpass, we will, with your consent given through the Singpass/Myinfo consent screen, retrieve from Myinfo the specific data items shown to you at the point of consent (which may include your name, NRIC/FIN, and work pass particulars). We use this data solely to verify your identity and complete your onboarding and account setup.

5.2 Myinfo data is retrieved in accordance with the terms of the Singpass ecosystem administered by GovTech Singapore. We retain only the data items reasonably necessary for the purposes in Section 3 and handle them with the safeguards described in Section 7.

6. AI Features, Voice Input and Transcription

6.1 Certain features of the App use artificial intelligence services — including the AI safety assistant, report pre-classification, guided form-filling, and speech-to-text transcription of voice recordings you choose to make. Content you submit to these features (including your voice audio and chat messages) is processed by our authorised cloud AI service providers for the purpose of providing the feature.

6.2 Our AI service providers process such content as our data intermediaries and are not permitted to use it to train their generalised AI models. AI-generated output (such as transcripts and suggested classifications) is provided to assist you and the Companies’ safety personnel; material safety decisions remain subject to human review.

7. Protection, Retention and App Permissions

7.1 We implement administrative, technical and physical safeguards to protect your Personal Data, including encryption of data in transit and at rest, role-based access controls, audit logging, and regular security assessments.

7.2 We retain Personal Data only for so long as it is reasonably necessary for the purposes set out in Section 3, or as required by applicable law (including WSH record-keeping obligations), after which we will delete, destroy or anonymise it. To request deletion of your account, see Delete your WorkSAFE account.

7.3 The mobile application requests the following device permissions, each only when you use the corresponding feature: camera and photo library (to attach photographs and videos to safety records), microphone (voice input and transcription), and notifications (safety alerts and status updates). You may withdraw these permissions at any time in your device settings; the related features will be unavailable but the rest of the App will continue to function.

8. Deemed Consent

8.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:

where, in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and
where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us, or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy.

9. Other Bases for Handling or Processing Your Personal Data

9.1 In addition to and without limiting the consents you have provided, where permitted by applicable law, we may collect, use and/or disclose your Personal Data without consent where we meet the requirements under applicable law, including:

for our legitimate interests or the legitimate interests of another person, including without limitation: workplace safety and the prevention of injury; any investigations or proceedings; fraud detection and prevention; managing an employment or engagement relationship; obtaining legal services; and detection and prevention of misuse of the App; and
where collection, use or disclosure is necessary to respond to an emergency that threatens the life, health or safety of any individual.

10. Contacting Us — Questions, Feedback, Withdrawal of Consent, Access and Correction

10.1 If you:

have any questions or feedback relating to your Personal Data or this Privacy Policy;
would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
would like to obtain access to or make corrections to your Personal Data records,

please contact us via our support channel at worksafe.support@stridesdigital.com.

10.2 If your Personal Data was provided to us by your employer or another third party, you may also need to direct queries, access or correction requests to that party.

10.3 If you withdraw your consent to any or all collection, use and/or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide you access to the App. Because the App supports the Companies’ statutory workplace safety obligations, certain records containing your Personal Data (such as incident reports) may need to be retained and processed notwithstanding a withdrawal of consent, where such processing without consent is permitted or required under applicable law. Our legal rights and remedies are expressly reserved.

11. Governing Law

11.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.