Personal Data Protection Policy
Section 1 – Introduction
- We, HHJ ENT Pte Ltd (the Company), value the privacy of every individual and are committed to protect the personal data we collect in accordance with the principles set out in this Policy.
- In accordance with The Personal Data Protection Act (“PDPA”), this Personal Data Protection Policy (“Policy”) describes how we may collect, use, disclose and manage your personal data. For general information on Personal Data Protection, please visit the Personal Data Protection Commission (“PDPC”) website at www.pdpc.gov.sg.
- Please note that though we make an effort to provide adequate information concerning our policies as it pertains to personal data, this PDPP is not an exhaustive list of all the situations and scenarios concerning personal data. Feel free to contact us if you need clarification about any specific situation.
- The PDPP applies and forms part of the terms and conditions governing our transactions and agreements with us, whenever your personal data is handled by us. The PDPP supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your personal data.
- We bring it to your attention and make it part of your transactions and agreements with us, by providing the Personal Data Protection Form upon the first admission as patient, and by making the PDPP available upon request.
- The PDPP, having been brought to your attention, becomes binding by taking of any of the following action:
- Proceeding with your transactions and agreements with us
- Submitting information to us via forms or other data collection means or processes (whether through the patient registration form or undergoing medical treatment)
- Attending at our premises for visits
- Calling or sending messages to us
- Transacting with us, or undergoing any treatment with us; and
- Other means
- We ask and require that all employees of HHJ ENT Pte. Ltd. abide by this PDPP.
Section 2 – Your Personal Data
- Personal data is defined as “data, whether true or not, about an individual who can be (i) identified from that data, or (ii) from that data and other information to which the organization has or is likely to have access to.” This may include your full name, identification number, passport, photograph, video mobile phone number, personal email address, thumbprint, DNA profile, as well as name and residential address of any individual which you have provided us.
- The PDPA does not apply to:
- Business contact information, defined as an individual’s name, position name or title, business telephone number, business address, business electronic mail address, business fax number and any other similar information not provided sole for the individual’s personal purposes.
- Personal data that is anonymized, i.e. identifying information is removed such that the remaining data does not identify any particular individual. The PDPC will consider the data anonymized only if the possibility of re-identification is trivial.
- Personal data of a deceased individual who has been dead for more than 10 years.
- Personal data that is falsified with the intent to commit fraud.
- HHJ ENT Pte Ltd practices and undertakes reasonable safeguards to anonymise personal data in appropriate situations, balancing both the need to rely on and use sufficiently accurate and complete personal data to protect life and health, and avoid mistakes, injury or accidents.
- The PDPA recognizes that a balance needs to be struck between the needs to protect personal data and the need of the organization to collect, use or disclose personal data. Hence, in meeting those obligations, PDPA considers what a reasonable person would consider appropriate in the circumstances wen they undertake any actin that is subject to data protection.
Section 3 – Consent
- By applying this PDPP, you:
- Consent to the clinic and the relevant persons handling your personal data in ways which enable us to provide you with the relevant services or to facilitate our interactions with you.
- Enable the exercising of your rights under the PDPA in an operative and applicable framework, including securing the right to access your personal data, withdraw (or manage) your consents and preferences as to your personal data.
- You are entitled under applicable law to withhold/withdraw consent to the collection, use or disclosure of personal data, and we will respect your choices in this regard. You may withhold consent at any juncture that you are asked for consent, and you may also apply the process/method to withdraw consent as stated in this PDPP (see Section 8 – Contacting Us).
- However, as recognized by and provided for under the PDPA, it may be that any choice you make to withhold or withdraw consent may impact our ability to proceed with your transactions or interactions with us, in particular:
- In some cases, it may also become unsafe or unlawful for us to provide (or continue to provide medical treatment with the ability to collect, use or disclose personal data.
- It may not be possible, with undue risk, cost or liability to the Company, to proceed with a particular transaction or interaction with you, and we may be left with no choice but to cease or refrain from the same.
- HHJ ENT Pte Ltd will take the approach that best safeguards us, you and others from risks, and we may well have no choice but to decline to proceed with the transactions or interaction in question to avoid causing harm or exposing us, you or others to risk.
- At the same time, it should be noted that your withholding/withdrawal of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitles to at law).
- Consent for the collection, use or disclosure of your personal data can be provided either in the form of expressed consent or deemed consent. Your provision of personal data to us is voluntary and you are deemed to consent to our collection, use or disclosure of your personal data under which it was collected. If you have consented to our disclosure of your personal data to other organizations for a particular purpose, they will use your personal data only for the purposes you have consented to.
- If you provide the personal data belonging to others, you warrant that you have informed the individuals of the purposes for which we are collecting their personal data and that they have consented to your disclosure of their personal data to use for those purposes.
- We also rely on you and will assume that you have ensured that all personal data submitted to us is complete, accurate, true and correct.
- If you fail to provide us with complete and accurate information, we may, in some situations, be prevented from providing a patient with medical treatment (or may be impaired in doing so, resulting in risks to that patient) or cause harm to a data subject.
- When using your personal data to contact you for the purposes under which you have consented, we may contact you via postal mail, electronic mail, SMS, telephone, fax or any other means.
Section 4 – Protection of Your Personal Data
- We will take reasonable efforts to protect personal data in our possession by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
- While we take reasonable efforts to protect your personal data held by us, we cannot be held responsible for unauthorized and unintended access that is beyond our control.
Section 5 – Retention of Your Personal Data
- We will retain personal data as may be required for business or legal purposes. While we will securely dispose of personal data which we can reasonably determine as no longer needed, it is in the interests of any healthcare professional treating the patient to be able to refer to a complete set of medical records to avoid risks to health and safety of the patient.
- Medical records covers all clinical encounters and inpatient and outpatient records generated at the time of admission or outpatient attendance. With accordance to MOH 2015 guidelines for the Retention Periods of Medical Records, it is advised that the retention period starts only after patients have turned inactive, or have passed away. This ensures that patients who require their medical records in the future will have access to them.
- As such, with respect to the medical records of patients, unless specific contrary instructions from the patient are received, HHJ ENT Pte Ltd may retain medical records for as long as the clinic may be potentially consulted for further follow up by the patient even where such consultation may not occur until after a substantial period of time or there is no current or present indication that the patient may well return for further consultation or follow up.
- We may anonymize your personal data on record as an organization is considered to have ceased retention of personal data when it no longer has the means to associate the personal data with particular individuals.
- We will retain employee personal data fir a reasonable period for up to 7 years in accordance with its legal and business purposes, even after the person ceases to be employed by the Company.
Section 6 – Contacting Us, Withdrawal of Consent, Access and Correction of Your Personal Data
- If you have any questions or feedback relating to your personal data or our PDPP, or would like to withdraw your consent to any use of your personal data as set out in this PDPP, or would like to obtain access and make corrections to your personal data records, please contact our Data Protection Officer as follows:
- Data Protection Officer
The ENT, Voice & Snoring Clinic
3 Mount Elizabeth, #12-13
- Data Protection Officer
- We may charge you a fee for the provision of your personal data held by us, or for information about the ways in which the data may have been used or disclosed in the past one year.
- We will not be able to provide access to data which are opinion data kept solely for evaluation purpose such as opinion of suitability, eligibility, qualification of individuals for employment, promotion or continuance in employment.
- Please note that if your personal data has been provided to us by a third party (e.g. general practitioners who refer you to us), you should contact such party directly to make any queries, feedback, and access and correction requests to HHJ ENT Pte Ltd, on your behalf.