The Management Corporation Strata Title Plan No. 3615

Background The Management Corporation Strata Title Plan No. 3615 (“ MCST 3615 ”) is responsible for the managing and maintaining common areas in the Suites@Cairnhill Condominium (the “ Condominium ”). MCST 3615 had engaged a managing agent (“ MA ”) for the Condominium. On 23 May 2024, the Personal Data Protection Commission (the “ Commission ”) received a complaint from a member of public (the “ Complainant ”) that he was denied access to CCTV footage allegedly containing his personal data for which he had raised an access request. The Complainant also alleged that the access request had not been handled in accordance with the Personal Data Protection Act 2012 (the “ PDPA ”). On 13 April 2024 at approximately 5am, the Complainant was riding a motorcycle along the Condominium’s Cairnhill Road perimeter when he collided with a taxi. The Complainant found that the Condominium had a CCTV camera facing its Cairnhill Road perimeter. On 20 May 2024, the Complainant submitted a written request for access to CCTV footage of the Cairnhill Road perimeter at the material time, which could have captured himself and/or the accident. The MA refused the request on 21 May 2024. Access Obligation Investigations revealed that MCST 3615 did not possess the personal data of the Complainant, as the Complainant could not be identified from the CCTV footage, whether by itself or with other information to which MCST 3615 has or is likely to have access. The Condominium’s CCTV had captured footage of a motorcycle riding along Cairnhill Road at the time of the accident. However, it had only captured the silhouette of the rider and did not capture any identifying features such as facial features or the license plate of the motorcycle. MCST 3615 also did not possess any other information to identify the individual from the footage. As MCST 3615 was not in the possession of the Complainant’s perso