I-Admin (Singapore) Pte Ltd v Hong Ying Ting
[2020] SGCA 32
issue faced by owners of copyrighted and confidential information, particularly
in the context of disputes arising out of erstwhile employer-employee
relationships. Against the backdrop of a digitised society, it is now significantly
more challenging to guard against the wrongful copying, abuse and exploitation
of protected information. This appeal provides us with a timely opportunity to
review the scope of the law of confidence in particular. We state at the outset
that, in our judgment, the legal framework that has hitherto prevailed does not
adequately safeguard the interests of those who own confidential information.
The facts
The parties
4
The appellant is a Singapore-incorporated company in the business of
outsourcing services and systems software, specifically payroll administrative
data processing services (“Payroll Systems”) and human resource (“HR”)
information systems (“HRIS”) (GD at [3]). The appellant’s Payroll Systems are
used by more than 800 clients in 15 countries across Asia and it operates a
number of wholly owned subsidiaries including I-Admin (Shanghai) Ltd (“IAdmin (Shanghai)”).
5
The appellant’s Payroll Systems come in two forms: the “payAdmin”
and “ePayroll” software systems. The “payAdmin” system is the appellant’s
core payroll calculation engine designed for large corporations. The “ePayroll”
system is a streamlined version of the “payAdmin” system and caters to small
and medium-sized clients. The appellant’s HRIS is a collective term to describe
the various HR systems it has developed. A number of other materials surround
and underlie these software systems, making up the infrastructure through
which the appellant operates its business and provides its services.
2
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