In an earlier article, TOC revealed that HappyDot.sg, which calls itself “an online survey community for Singapore residents“, is actually owned by an entity called Rysense Ltd.
Rysense is a Company Limited by Guarantee (CLG) rather than a Private Limited Company. This is unusual, because the CLG structure is normally only used by non-profit organisations such as charities and religious organisations.
Why would Rysense have such an unusual structure compared to most small businesses which are Private Limited Companies?
The answer is found in ACRA records showing that all of the directors of Rysense are senior civil servants from the Prime Minister’s Office, the Ministry of Communications and Information (MCI) or the Government Technology Agency (GovTech).
Given the composition of its Board of Directors, Rysense appears to be fully-owned and controlled by the Government, and is a captive supplier with the Government as its only customer.
Based on social media reports (here and here), HappyDot.sg’s parent company, Rysense, regularly conducts face-to-face and telephone surveys on issues related to government policy and public sentiment.
HappyDot.sg appears to be Rysense’s attempt to develop an online survey platform to complement the offline surveys it conducts for the Government.
Singaporeans and Permanent Residents are given S$10 shopping vouchers in exchange for signing up with HappyDot.sg and rewarded with points for responding to online surveys.
These points can then be redeemed for more shopping vouchers.
HappyDot.sg does not disclose that it is “owned” by the Government. Instead, it obscures its funding sources by saying that it conducts surveys “on behalf of organisations with an interest in specific social issues.”
This is in contrast to its parent company, Rysense, which at least informs survey participants that its surveys are commissioned by the Government.
Given that HappyDot.sg uses the tagline “Inspiring positive change in Singapore”, one must ask whether HappyDot.sg is going beyond just surveying public opinion, or is attempting to shape public opinion by publishing articles on public policy issues without disclosing that it is under the Government’s purvey.
It is common for Government agencies to conduct public education campaigns in all forms of media — however, they will normally include their name and logo in all advertisements and other publicity materials.
In contrast, HappyDot.sg does not disclose that it is controlled by the Government on its website or any of the articles that it publishes.
When a reader reads an article on the social safety net, for example, would he read it differently if he knows that the publisher is “owned” by the Government, compared to if he just thinks that the publisher is an internet marketing company?
Ironically, even as the Government warns of the dangers of astroturfing — the creation of a false impression of widespread grassroots support or opposition to a particular issue — when justifying the Prevention of Online Falsehoods and Manipulation Act (POFMA), its ownership of HappyDot.sg gives it a tool which could be used to push out Government messages under the guise of a private company.
Even though the Government says that it does not govern by opinion polls, it is reasonable for any government to want to use opinion polls to gauge public sentiment.
When a public agency commissions polls, however, it should ensure that pollsters disclose to participants that the survey is commissioned by the agency, regardless whether the survey is conducted in-person, over the phone, or online.
There is, however, little to no information on who commissions the surveys conducted by HappyDot.sg.
Even in the sole results from online searches, MCI labelled HappyDot.sg as a third party company in a release on 6 August 2018, when we know now from ACRA records that it is in fact “owned” and “run” by the government indirectly.
Specifically, HappyDot.sg should af least inform its participants that it is linked to the Government when users sign up on the site, and again when it asks its users to participate in surveys commissioned by the Government.
Furthermore, articles on issues of public interest carried on HappyDot’s website should include a disclosure that HappyDot.sg is “owned” by the Government, so that readers will not be misled into thinking that it is an independent organisation.