How S&P Group of Companies Pte. Ltd. collects, uses, and protects personal data in the SP Group application.
Effective 10 August 2026
1. Who we are
S&P Group of Companies Pte. Ltd. (UEN 202445619R), a company incorporated in Singapore on 6 November 2024 with its registered office at 2 Venture Drive, #14-22, Vision Exchange, Singapore 608526, operates the SP Group mobile and web application ("the App"). In this policy, "we", "us" and "our" refer to that company.
The App is the client for FullERP, an enterprise resource planning platform for construction and facilities businesses. It is licensed to employer organisations ("Customers"), whose workers and administrators use it. Where a Customer other than us decides how your data is used, that Customer is the data controller and we act as its data intermediary; this policy then describes our own handling, and your employer's own notice governs theirs.
This policy is issued under Singapore's Personal Data Protection Act 2012 ("PDPA"). Where a Customer or a user is in a jurisdiction with additional requirements, we apply those requirements to that user's data.
2. Our Data Protection Officer
You can reach our Data Protection Officer about anything in this policy, to exercise any right described in section 9, or to complain:
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Email: dpo@spgroupsg.com
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Post: Data Protection Officer, S&P Group of Companies Pte. Ltd., 2 Venture Drive, #14-22, Vision Exchange, Singapore 608526
3. What personal data we collect
We collect only what the App needs to run the employment, payroll, attendance and accommodation functions your employer has licensed. The categories below are exhaustive for the App.
Identity
Full name, parents' names where required for work-pass processing, date of birth, gender, nationality, photograph.
Government identifiers
FIN or NRIC number, passport number and expiry date, work permit / S Pass / Employment Pass number and validity. Collected because Singapore employment and immigration law requires an employer to hold them.
Contact
Email address, mobile number, residential or dormitory address, emergency contact.
Employment
Employee code, company, branch, department, designation, project or client-site assignment, skill classification, joining and leaving dates, disciplinary and performance records where your employer uses those modules.
Financial
Basic salary, allowances, deductions, overtime, CPF contributions, tax withholding, bank account details for salary payment, loans and salary advances.
Attendance and precise location
Check-in and check-out timestamps; precise GPS coordinates, accuracy and altitude captured at the moment you punch; the site or geofenced zone matched to that punch; and, only while a shift is running, the movement path, speed and distance used to verify the punch. See section 5.
Device
A stable device identifier (Android SSAID, or the iOS identifierForVendor), device model, operating system version, and App version. See section 6.
Accommodation and welfare
Dormitory, room and bed assignment, occupancy and transfer history, and meal or catering records where your employer uses those modules.
Account and security
Username, password (stored only as a salted cryptographic hash — never in readable form), session and refresh tokens, login timestamps, IP address, and an audit trail of actions taken in the App.
Enquiries
If you use the public contact or job-application form on our website: your name, email, phone, message and any details you choose to include.
4. Where the data comes from
Most personal data in the App is provided by your employer from its own employment records when your account is created — you do not re-enter it. You provide data directly when you register for access, update your profile, submit a leave or claim request, or punch attendance. The App generates data about you when you use it: timestamps, audit entries, and the location and device signals described below.
We do not buy personal data from data brokers and we do not enrich your record from third-party sources.
5. Location data — what we do and do not do
Location is the most sensitive thing the App handles, so we are specific about it.
Foreground location. When you press check-in or check-out, the App reads your precise position once and, while the shift screen is open, follows it so it can confirm you are inside the correct work site and record the distance travelled during the shift. This runs only while you are using the App.
Background location. Background location is strictly optional and is OFF unless you switch it on. If you enable "Automatic site check-in", the operating system watches a small number of geofenced circles around your assigned work sites and wakes the App only when you cross the edge of one, so that your arrival or departure can be recorded without you opening the App. We receive the crossing event and the coordinates of that crossing. We do not stream continuous background location, we do not build a movement history outside your shift, and we do not track you outside your assigned sites.
You can turn "Automatic site check-in" off inside the App at any time, and you can withdraw the operating-system permission at any time in your device settings. Turning it off stops all background collection immediately; the rest of the App, including manual check-in, keeps working.
We never sell location data, never share it for advertising, and never use it to infer anything beyond attendance at a work site.
6. Device identifiers and attendance fraud prevention
Time-fraud — one worker punching in for another — is the single largest integrity risk in a workforce attendance system. To detect it, the App records a stable per-device identifier and compares it against the device you registered.
On Android we use the Settings.Secure.ANDROID_ID (SSAID); on iOS, identifierForVendor (IDFV); on the web, a hardware fingerprint derived from rendering characteristics. We deliberately do NOT collect the IMEI, MAC address, advertising identifier, or any device serial number.
This identifier is linked to your employee record for the sole purpose of fraud prevention and security, and never for advertising, analytics or profiling. It is retained for as long as the associated attendance record is retained, and is deleted with it.
7. Why we use your data, and our legal basis
Administering your employment: attendance, rosters, leave, payroll, claims, accommodation and transport.
Necessary for the performance of your employment contract, and consented to under the PDPA when you accept your employer's terms.
Compliance with legal obligations to which we and your employer are subject.
Verifying that attendance punches are genuine, and detecting buddy-punching, location spoofing and device sharing.
Our legitimate interest, and your employer's, in accurate payroll and in preventing fraud.
Securing the platform: authentication, session management, audit logging, and investigating misuse.
Legitimate interest in the security of the service, and legal obligation.
Automatic site check-in using background location.
Your explicit, separately given, freely withdrawable consent.
Responding to enquiries and job applications submitted through our website.
Consent, and steps taken at your request before entering a contract.
8. Who we share it with
We do not sell personal data. We do not share it with advertising networks, data brokers, or any third party for their own marketing. The App contains no third-party advertising or analytics SDKs.
We disclose personal data only to:
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Your employer, and the personnel within it who are authorised to see it. The App enforces this with role-based access control and organisational scoping, so a manager sees their own workers and not another company's.
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Government authorities where the law requires it — for example the Ministry of Manpower, the Central Provident Fund Board, or the Inland Revenue Authority of Singapore.
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Service providers who host and operate the platform on our behalf, under contract, bound to confidentiality and permitted to use the data only to provide the service. Our hosting is provided by Amazon Web Services in the ap-southeast-1 (Singapore) region.
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Professional advisers, auditors and insurers where necessary, and to a successor entity in the event of a merger or acquisition, subject to the same protections.
9. Your rights
Under the PDPA, and under comparable law where it applies to you, you may:
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Ask what personal data we hold about you and how it has been used or disclosed in the past year (access).
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Ask us to correct anything inaccurate or incomplete (correction).
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Withdraw a consent you have given, including for background location, at any time.
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Ask us to delete your account and personal data — see section 11 and the Account Deletion page.
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Ask for a copy of data you supplied, in a commonly used machine-readable form (portability).
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Complain to us, and, if you remain dissatisfied, to the Personal Data Protection Commission of Singapore.
10. How long we keep it
We keep personal data only as long as we need it, or as long as the law obliges us to. Where a statutory minimum applies, it overrides your deletion request for that specific record — we will tell you when this happens and delete the record as soon as the period expires.
Account credentials and session data
Deleted within 30 days of account deletion.
Attendance and location records
Deleted within 30 days of account deletion, unless still within the employment-records period below.
Employment records
For current employees, the latest 2 years. For former employees, the last 2 years of records, kept for 1 year after employment ends — the minimum set by the Singapore Employment Act.
CPF contribution records
5 years, as required by the Central Provident Fund Act.
Payroll and tax records
5 years, as required by the Income Tax Act and IRAS record-keeping rules.
Work-pass and immigration records
For the duration of the pass and as long afterwards as the Ministry of Manpower requires.
Security and audit logs
Up to 12 months, then deleted.
Website enquiries and job applications
12 months, unless you ask us to delete them sooner.
11. Deleting your account
You can request deletion of your account and personal data from inside the App — open the profile menu and choose "Delete my account" — or from the Account Deletion page on our website, without needing to install the App.
We confirm the request, disable the account immediately so it can no longer be used, and erase the personal data within 30 days, except for the specific records that section 10 obliges us to retain for a statutory period. Anything retained is locked down to the personnel who need it for that legal purpose and is deleted as soon as the period ends.
If you are a current employee, deleting your App account removes your access to the App; it does not by itself end your employment or erase the employment records your employer is legally required to keep.
12. How we protect it
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All traffic between the App and our servers is encrypted in transit with TLS. The App will not transmit over an unencrypted connection.
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Passwords are stored only as salted cryptographic hashes and are never recoverable, by us or by anyone else.
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Access is controlled by role and by organisational scope, enforced on the server, and is denied by default. Sessions expire and tokens can be revoked centrally.
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The database runs under a least-privilege account with no administrative rights, and every change to a personal record is written to an audit trail.
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Data is hosted in Singapore (AWS ap-southeast-1). Where any processing occurs outside Singapore, we ensure a comparable standard of protection as the PDPA requires.
13. Children
The App is a workplace tool intended for people of legal working age. It is not directed at children, we do not knowingly collect data from anyone under 16, and there is no route by which a child could create an account — accounts are issued by employers. If we learn that we hold a child's data, we delete it.
14. Changes to this policy
If we change this policy we will update the effective date above, and we will notify you in the App before a material change takes effect. Continuing to use the App after that date means you accept the updated policy. Where a change requires your consent, we will ask for it separately rather than assume it.
15. Contact us
Questions, requests or complaints about this policy should go to our Data Protection Officer at dpo@spgroupsg.com, or by post to S&P Group of Companies Pte. Ltd., 2 Venture Drive, #14-22, Vision Exchange, Singapore 608526. We aim to acknowledge within 3 business days and to respond substantively within 30 days.