Personal Data Protection Policies (for Patient and Corporate) – Farrer Park Hospital

Personal Data Protection Policies (for Patient and Corporate)

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Farrer Park Hospital Pte. Ltd.’s Personal Data Protection Policy (Patient) 
(revised 29 May 2017)​
This is the personal data protection policy of Farrer Park Hospital Pte. Ltd. In this policy, the terms “we”, “us” and “our” refer to Farrer Park Hospital Pte. Ltd. and the term “TFPC Group” refers collectively to us, our parent company The Farrer Park Company Pte. Ltd. and/or its subsidiaries. 

We are committed to data protection. We will follow this policy and comply with all data protection and confidentiality obligations imposed on us by law, including the Personal Data Protection Act 2012 (No. 26 of 2012) and Private Hospitals and Medical Clinics Act (Cap. 248) of Singapore.

What personal data we collect 
Personal data is data that can be used to identify a natural person. Examples of personal data include your name, nationality, date of birth, sex, contact details (address, email address, telephone numbers), NRIC, FIN or passport number, your image on our close-circuit television (CCTV) and in photographs, your medical history, patient history, allergy information and any other medical and health records. Where required and medically necessary for diagnostic, treatment and record purposes, we may also take photographs of your wound(s).  

If you provide the personal data of anyone else (such as your family members or next-of-kin), it means that you have obtained his/her consent to our collection, use and disclosure of his/her personal data for the purposes set out in this policy or that you validly give us such consent on their behalf.
Our purposes for collection, use and disclosure of personal data 
We collect, use and disclose personal data for the following purposes: 

Healthcare and other services
o providing inpatient and outpatient medical treatment and services, healthcare and allied healthcare services;
o management and coordination of your care including follow-ups, step-down care and other continuity of care issues; and/or
o providing all other services on request or as needed, including customer service, patient liaison services, travel and accommodation arrangements, concierge services, porter, butler and housekeeping services, laundry services, ambulance services, arrival/departure transport services, security and guarding services and other products and services made available by us, other TFPC Group entities and our respective partners.

Administration
o processing appointments, bookings, admissions, transfers and discharge;
o processing and collecting payment for products, treatment and services;
o reimbursement of healthcare providers for services provided to you;
o creation, storage, hosting, backup (whether for disaster recovery or other purposes) of medical records and financial and other business records;
o verifying identity and conducting screenings, due diligence checks and credit checks;
o responding to queries or feedback;
o addressing or investigating complaints, claims or disputes;
o compliance with internal policies, procedures and directives; 
o enforcing obligations owed to us; and/or
o complying with our legal obligations and requirements.

Business operations
o guarding and securing our premises;
o monitoring and assessing the provision of products and services;
o financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
o business research, planning, statistical analysis and policy development; and/or
o enhancing and improving our services, including reviewing standards of care

Health information sharing
o Sharing medical records with other health care providers for medical treatment and health care purposes, where required or permitted by law, including by way of the National Electronic Health Record (NEHR) system, which enables health information to be shared throughout the Singapore healthcare ecosystem.

Teaching purposes
o Providing education and training for doctors and other medical, nursing or health professionals and students. You are entitled to say no at any time to such persons viewing or being granted access to your treatment and related information. Please inform your doctor before treatment if you do not want such persons to view or have access to your treatment and related information.

Research
o Conducting research into new treatments, procedures and practices for the improvement of healthcare, subject always to applicable laws and codes of conduct, including those relating to the protection of research subjects’ safety and confidentiality.

Marketing and promotion
o With your consent, conducting marketing and promotion in relation to us, other TFPC Group entities and/or our respective partners.
o We will not send telemarketing messages to your Singapore telephone number via text messages, telephone calls or facsimile transmission if we do not have your clear and unambiguous consent in writing or other recorded form to do so or if you have made the appropriate registration of your number with the Do Not Call Registry.

Public health purposes
o Safeguarding public health and safety and preventing or lessening the threat to your health and safety or the health and safety of others.

Photography and CCTV (closed-circuit television) 
o We may take photographs and make videos and/or sound recordings in and around our premises from time to time, including our meeting and function rooms. You may be captured in such photographs and recordings. 
o We may use such photographs and/or recordings in our publications, websites and other communication channels, as well as in third party media, or display them in and around our premises and/or the premises of the TFPC Group. 
o CCTV may be in operation in and around our premises as necessary in the interests of security.

Any other purposes relating to or arising out of the above

We may disclose the personal data to third parties, whether located in Singapore or elsewhere, in order to achieve the purposes stated in this policy. Such third parties include:

the doctors and other healthcare professionals who treat or have treated you, and their respective staff;
the Central Provident Fund Board of Singapore and/or your health insurance provider, for payment processing purposes;
other TFPC Group entities and our respective partners for the provision of products and services at your request or the conduct of marketing and promotions with your consent;
our service providers, contractors and agents;
third parties that you have used to obtain or request our products and services, including referral agencies, business introducers, travel agencies or similar service providers;
other TFPC Group entities for group-wide business purposes or where such disclosure is required or permitted by law;
healthcare providers, agencies or facilities for the purposes of information sharing and exchange via the NEHR system or other health information exchange systems, where such disclosure is required or permitted by law;
regulatory authorities, any statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives or where such disclosure is required or permitted by law, including the Ministry of Health, Health Sciences Authority, the coroner and the police and other law enforcement agencies 
funeral homes and crematoria, where such disclosure is required or permitted by law;
organisations that handle organ donation, procurement and transplants, where such disclosure is required or permitted by law;
national registers and databases for various medical conditions, diseases and transplants, where such disclosure is required or permitted by law;
accreditation or representative bodies for health care providers, agencies, facilities or healthcare professionals, where such disclosure is required or permitted by law; and/or
anyone involved in your care or payment for your care (including a family member, friend or your caregiver or caregiving organisation) and anyone you have authorised us to contact or communicate with. 

We may also collect, use and disclose personal data where required or permitted by law for any purpose.

In order to achieve any of the purposes referred to above, we may need to transfer personal data outside Singapore. If we do so, we will ensure that such personal data is protected to a standard comparable to the protection accorded to personal data under the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore. In summary, this means: 

the collection, use and/or disclosure of your personal data would be for the purpose(s) for which you have given consent; 
steps would be taken to ensure accuracy and completeness of your personal data when your personal data is used or disclosed to third parties;
security arrangements would be made to protect your personal data;
your personal data would be retained only if necessary for legal and business purposes; and/or
anyone who receives your personal data from us is either in a jurisdiction which has comparable data protection laws or is otherwise bound to protect your personal data.

Risks on relying on data we collect from you that is without consent or which is inaccurate 
If consents are not procured or if you fail to provide us with complete or 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.

We will take the approach that best safeguards us, you and others from risks, and we may well have not choice but to decline to proceed with the treatment in question to avoid causing harm or exposing us, you or others at risk.

Retention of personal data​
We will retain personal data for a reasonable period in accordance with our legal and business purposes.

Access to and correction of personal data
If you wish to correct or have access to your personal data, please contact us. See the “How to contact us” section at the end of this policy. We may charge a reasonable fee for processing a request for access to personal data.

How to contact us
If you have questions or concerns regarding your personal data or any aspect of this policy, please contact us at pdpa@farrerpark.com.

Amendments and updates
We may amend this policy from time to time and will make available the updated policy on our Internet site at www.farrerpark.com​. Each time we collect, use or disclose personal data, the latest version of this policy in force at the time will apply.
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Personal Data Protection Policy (Corporate)
(effective 2 July 2014)
​This is the data protection policy of The Farrer Park Company Pte. Ltd. for handling personal data collected from or about our clients. In this policy, the terms “we”, “us” and “our” refer to The Farrer Park Company Pte. Ltd. and the term “TFPC Group” refers collectively to us and/or our subsidiaries.

What personal data we collect 
Personal data is data that can be used to identify a natural person. Examples of personal data include your name, nationality, date of birth, sex, contact details (address, email address, telephone numbers), passport or other identification number, your image on CCTV and in photographs and your medical history, patient history, allergy information and any other medical and health records. If you provide the personal data of anyone else (such as anyone you book order our products or services for), it means that you have obtained his/her consent to our collection, use and disclosure of his/her personal data for the purposes set out in this policy or that you validly give us such consent on their behalf.

Our purposes for collection, use and disclosure of personal data 
We collect, use and disclose personal data for the following purposes: 

 Serving our customers
o providing products and services as requested;
o providing benefits and entitlements to subscribers of our loyalty programs, which may include the promotion of products and services of the TFPC Group and our partners;
o responding to queries or feedback; and/or
o addressing or investigating complaints, claims or disputes

 Administration
o processing applications and bookings for products and services;
o processing and collecting payment for products and services provided;
o creation, storage, hosting, backup (whether for disaster recovery or other purposes) of customer records and financial and other business records; and/or
o verifying identity and conducting screenings, due diligence checks and credit checks.

 Business operations
o guarding and securing our premises;
o monitoring and assessing the provision of products and services;
o financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
o business research, planning, statistical analysis and policy development;
o enhancing and improving our services;
o compliance with internal policies, procedures and directives;
o enforcing obligations owed to us; and/or
o complying with our legal obligations and requirements.

 Marketing and promotion
o With your consent, conducting marketing and promotion in relation to us, other TFPC Group entities and/or our respective partners.
o We will not send telemarketing messages to your Singapore telephone number via text messages, telephone calls or facsimile transmission if we do not have your clear and unambiguous consent in writing or other recorded form to do so or if you have made the appropriate registration of your number with the Do Not Call Registry.​

• Photography and CCTV (closed-circuit television)
o We may take photographs and make videos and/or sound recordings in and around our premises from time to time, including our conference venues and function rooms. You may be captured in such photographs and recordings.
o We may use such photographs and/or recordings in our publications, websites and other communication channels, as well as in third party media, or display them in and around our premises and/or the premises of the TFPC Group.
o CCTV may be in operation in and around our premises as necessary in the interests of
security.

 Any other purposes relating to or arising out of the above
We may disclose the personal data to third parties, whether located in Singapore or elsewhere, in order to achieve the purposes stated in this policy. Such third parties include:

 other TFPC Group entities and our respective partners for the provision of products and services at your request or the conduct of marketing and promotions with your consent;
 our service providers, contractors and agents;
 third parties that you have used to obtain or request our products and services, including referral agencies, business introducers, travel agencies or similar service providers;
 other TFPC Group entities for group-wide business purposes or where such disclosure is required or permitted by law;
 regulatory authorities, any statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives or where such disclosure is required or permitted by law; and/or
 anyone involved in the payment for products and services provided to you, anyone you have authorised to use our products and services and anyone you have authorised us to contact or communicate with.

We may also collect, use and disclose personal data where required or permitted by law for any purpose.
In order to achieve any of the purposes referred to above, we may need to transfer personal data outside Singapore. If we do so, we will ensure that such personal data is protected to a standard comparable to the protection accorded to personal data under the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore. In summary, this means:
• the collection, use and/or disclose your personal data would be for the purpose(s) for which you
have given consent;
• steps would be taken to ensure accuracy and completeness of your personal data when your personal data is used or disclosed to third parties;
• security arrangements would be made to protect your personal data;
• your personal data would be retained only if necessary for legal and business purposes; and/or
• anyone who receives your personal data from us is either in a jurisdiction which has comparable data protection laws or is otherwise bound to protect your personal data

Retention of personal data​

We will retain personal data for a reasonable period in accordance with our legal and business purposes.

Access to and correction of personal data
If you wish to correct or have access to your personal data, please contact us. See the “How to contact us” section at the end of this policy. We may charge a reasonable fee for processing a request for access to personal data.

How to contact us
If you have questions or concerns regarding your personal data or any aspect of this policy, please contact us at pdpa@farrerpark.com.

Amendments and updates
We may amend this policy from time to time and will make available the updated policy on our Internet site at www.farrerpark.com​. Each time we collect, use or disclose personal data, the latest version of this policy in force at the time will apply.
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