RENALTEAM PERSONAL DATA PROTECTION POLICY (PATIENT) EFFECTIVE FROM 2 JULY 2014
This is the patient personal data protection policy of RenalTeam Pte Ltd. In this policy, the terms “we”, “us” and “our” refer to RenalTeam Pte Ltd and the term “RT” refers collectively to us.
We are committed to data protection and 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).
1.0 PERSONAL DATA COLLECTION
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 CCTV and in photographs, 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 your family members), 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.
2.0 PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We collect, use and disclose personal data for the following purposes:
2.1 Healthcare and other services
- providing outpatient dialysis treatment and services;
- management and coordination of your continuity of care including follow-ups after your discharge from hospitals in the course of your receiving kidney dialysis treatments from us; and/or
- providing all other services on request or as needed, including customer service, patient liaison services, travel arrangements eg calling for a taxi to bring you home
- processing appointments, bookings, admissions, transfers and discharge;
- processing and collecting payment for treatment and services;
- creation, storage, hosting, backup (whether for disaster recovery or other purposes) of
- medical records and financial and other business records;
- verifying identity and conducting screenings, due diligence checks and credit checks;
- responding to queries or feedback;
- addressing or investigating complaints, claims or disputes;
- compliance with internal policies, procedures and directives;
- enforcing obligations owed to us; and/or
- complying with our legal obligations and requirements.
2.3 Business operations
- guarding and securing our premises;
- monitoring and assessing the provision of services and medication;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enhancing and improving our services, including reviewing standards of care
2.4 Health Information Sharing
- Sharing your medical records with other health care providers for medical treatment and healthcare 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.
- Conducting research into new procedures and practices for the improvement of providing kidney dialysis services and treatment, subject always to applicable laws and codes of conduct, including those relating to the protection of research subjects’ safety and confidentiality.
2.6 Photography and CCTV (closed-circuit television)
- 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.
- 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 RT.
- CCTV may be in operation in and around our premises as necessary in the interests of
2.7 Any other purposes relating to or arising out of the above
3.0 DISCLOSURE OF DATA TO THIRD PARTIES
We may disclose your 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 (“CPF Board”) and/or your health insurance provider, for payment processing purposes;
- RT 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;
- 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.
3.1 We may also collect, use and disclose personal data where required or permitted by law for any purpose.
4.0 RETENTION OF PERSONAL DATA
We will retain personal data for a reasonable period in accordance with our legal and business purposes. RT will therefore retain and maintain its personal data records in compliance with Ministry of Health licensing terms and conditions for Renal Dialysis under Regulation 18 (1) and Second Schedule and the Regulation 37 and Third Schedule of the Private Hospitals and Medical Clinics Regulations (Cap 248, Regulation 1), CPF Board and other regulatory bodies as part of its operating licensing terms and conditions.
5.0 ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to correct or have access to your personal data, please contact us under Clause 6 “Our Contact”.
6.0 OUR CONTACT
If you have questions or concerns regarding your personal data or any aspect of this policy, please contact us at firstname.lastname@example.org. Or, you may approach our Nurse Managers at the Dialysis Centre you are dialysing at.
RT will make information on data protection policies and procedures available upon written request.
Feedback may be provided anytime to the Data Protection Officer at RT’s HQ’s address. RT will consider all feedback and take appropriate action upon such feedback.
7.0 AMENDMENTS AND UPDATES
We may amend this policy from time to time and will make available the updated policy on our Website at www.renalteam.org. Each time we collect, use or disclose personal data, the latest version will apply.
RenalTeam Pte Ltd, its subsidiaries and affiliated entities are committed to data protection and have established a Personal Data Protection Policy. This policy sets out what information we may collect, how we may use that information and describes the measures we take to protect the data that we may collect from you when you use this website.
Collection of Personal Data
We may collect the following information:
- Name, gender, nationality, date of birth,
- National identification number/passport number,
- Basic medical history,
- Contact information including phone number and email address,
- Photographs, video and CCTV footages.
Purpose for the collection, use and disclosure of Personal Data
We may collect your personal data for the following purposes:
- To conduct data analysis for the improvement of our services and products
- To keep you updated on our products, services and events
- To keep you updated on changes to our policies
- To respond to and handle your queries, feedback and complaints
- To facilitate attendance at events/ functions that we may organise
- To carry out administrative and health care operations, including publicity and promotion of our services
Protection and Security of Personal Data
We are committed to ensuring that your information is secure. We employ a range of technological and physical arrangements and maintain safeguards to protect against the accidental or unauthorised access, collection, use, disclosure, copying, modification, disposal and deletion of Personal Data and other similar risks. While we use reasonable efforts to protect personal data in our possession or under our control, the transmission of data over the internet or any other public network may be subject to loss, interception and misuse.
Retention of your Personal Data
We only retain Personal data for as long as reasonably required for the purpose for which we collect the information.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites which we think may be of interest to you, However, once you leave our site, do note that we do not have any control over the other website. We are not responsible for the data protection practices of the websites operated by third parties that are linked to our website. We encourage you to know about the data protection practices of such third- party websites.
Withdrawal of Consent
Please contact us at email@example.com should you wish to withdraw your consent to any use of personal data as set out in this policy. Please note that if you withdraw your consent to the use of personal data, depending on the nature of your request, we may not be able to provide our services and products to you.
If you have any questions or feedback regarding your personal data or any aspect of this policy, you may contact us at firstname.lastname@example.org.
Updates to the Personal Data Policy
We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes of updates.
3rd August 2018