i-CARE PCN PTE. LTD. (i-CARE PCN) Personal Data Protection Policy Statement
We at i-CARE PCN take our responsibilities under Singapore’s Personal Data Protection Act 2012 (PDPA) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (DPO) at: email@example.com
INTRODUCTION TO THE PDPA
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video image
1.2 We may collect your personal data in the following ways:
when you interact with us or our staff, for example, via our website, emails and WhatsApp;
when you submit any form;
when you respond to or register for any of our promotions, initiatives or events;
when you submit an employment application;
when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;
when you submit your personal data to us for any other reason;
any other methods which we notify you of at the time of collection.
If you provide us with any personal data belonging to third parties (e.g. information of your parents, spouse, children, and/or employees), by submitting such information to us, you warrant that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.
2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
(a) providing i-CARE PCN and its stakeholders, including the Ministry of Health (MOH), the Agency for Integrated Care (AIC), i-CARE PCN’s associated clinics, amongst others;
(b) administering and/or managing your care either directly through i-CARE PCN’s employees or indirectly by referral to other medical clinics or institutions;
(c) carrying out your instructions or responding to any enquiries by you;
(d) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures (including but not limited to those designed to help you;
(e) dealing in any matters relating to the services and/or products which you have been prescribed to undertake;
(f) complying with applicable law in administering and managing your medical conditions;
(g) any other purposes which we notify you of at the time of obtaining your consent.
(collectively (a)-(g), the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.2. In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third-party service providers, agents and/or our affiliates or related medical clinics, and/or other third parties, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related medical clinics and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is to carry out i-CARE PCN responsibilities and deliverables, amongst others, to Singapore’s Primary Care Network;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for medical processes or advice to be provided to you;
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/.
3.4. Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4. REQUEST TO WITHDRAW CONSENT
4.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to your clinic under i-CARE PCN.
4.2 We will process your request from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
4.3 However, your withdrawal of consent could result in loss of Primary Care Network support arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue assisting you.
5. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
5.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by i-CARE PCN to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
5.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
5.3 We retain personal data in accordance with legal, regulatory, business and operational obligations.
6. FEEDBACK PROCESS
6.1 If you have any feedback regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your feedback via firstname.lastname@example.org. Attention it to the ‘Data Protection Officer’.