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Privacy Policy

DATA PROTECTION NOTICE FOR CUSTOMERS

 

This Data Protection Notice (“Notice”) sets out the basis which Etern Medical (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

 

PERSONAL DATA 

 

“Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Some examples of your Personal Data that we may collect are your name, contact details, residential address, date of birth, identification card number/passport details, medical records, third party referrals diagnostic imaging, photographic films and financial information and your current/previous medical history.  


We use reasonable precautions to protect your Personal Data under our control in order to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. We will use best endeavours to protect the security of your information and will periodically review and enhance our information security measures where necessary.

  • during your registration with us; including verification, maintenance and updating of data

  • during consent taking to procedures;

  • during your consultations with our healthcare professionals

  • provision of medical care to you to meet your medical needs, including referrals to other healthcare professionals, institutions, laboratories and other associated purposes (e.g. billing and internal administration).

  • notifying me by SMS and other means of appointment confirmations and reminders; clinic updates of information

  • filing of medical claims on your behalf with the relevant company, employer or insurance provider;

  • accounting, auditing and the maintenance of proper book-keeping for the operations and business

  • where there is a serious and imminent threat to an individual’s life, health, or safety;

  • where there is a serious threat to public health or public safety;

  • resolving complaints and dealing with enquiries made by you;

  • maintenance and updating of the data;

  • verification and identification purposes;

  • administrative or operational purposes;

  • processing credit notes and processing refunds;

  • collection of fees, charges and expenses for services provided including bank transfers or other means.

  • compliance with the applicable laws and regulations.

 

Purpose For The Collection, Use and Disclosure Of Your Personal Data

 

When you seek care at our medical clinics, your Personal Data may be disclosed / shared with healthcare professionals (such as doctors, clinic assistants, nurses, who are assisting on or providing medical treatment / services) and other medical institutions / facilities (including labs, diagnostic centers, TPA providers etc.). In each case the disclosure or sharing of such personal data is solely to such persons or entities which are involved in the care of the patient.

Please be assured that if your Personal Data is collected, used or disclosed for these purposes, we will protect it as required under the PDPA and other relevant legislation such as the Private Hospitals and Medical Clinics Act.

 

Retention of your Personal Data
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We will periodically review the Personal Data collected by us to determine if that data is still needed. Your Personal Data will be retained only as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.

 

Withdrawal of Consent Access and Correction of your Personal Data

 

It is your obligation to ensure that all Personal Data submitted to us is complete, accurate, true and correct. You have the right however, under the PDPA, to withdraw your consent to any use of your Personal Data, to obtain access or to make corrections to your Personal Data records kept with us.

 

You may at any time withdraw your consent for receiving marketing communications or any other purpose for which you have previously consented to by providing us with notice through a request submitted to the DPO,  your doctor or Medical Receptionist, where applicable.

Please be aware that once we receive confirmation that you wish to withdraw your consent to receiving marketing communications, it may take up to thirty (30) working days for your withdrawal to be reflected in our systems. During this period of time you may still receive marketing communications from us.

On receipt of such notice, the Practice will inform you of the likely consequences of withdrawing your consent. Depending on the nature of the withdrawal of consent, we may no longer be in a position to continue to providing our services to you. Such a withdrawal may therefore result in the termination of any doctor-patient relationship that you may have with us.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA

 

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

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2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

 

3. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

PROTECTION OF PERSONAL DATA

 

1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

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2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

3. We maintains personal data in the format of electronic files. We will protect your personal data with appropriate safeguards and security measures to prevent misuse, loss and unauthorized access, modification and disclosure.

 

4. Access to personal data will be authorised only for the physicians and employees, other agents who require access in the performance of their duties, and to those otherwise authorised by law. We provide personal data to health care providers acting on your behalf, on the understanding that they are also bound by law and ethics to safeguard your privacy.

 

5. Our computer systems are password-secured and constructed in such a way that only authorised individuals can access secure systems and databases. 

 

 

ACCURACY OF PERSONAL DATA

 

1. We endeavour to ensure that all decisions involving your personal data are based upon accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all relevant information and to inform us of any significant changes.

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2. While all reasonable efforts will be made to keep your personal data accurate, you are kindly requested to disclose all relevant information, inform us of any change and to ensure that all your personal data that is submitted to us is current, complete, accurate, true and correct.

 

 

RETENTION OF PERSONAL DATA

 

1. As per the Ministry of Health requirements; we reserve the right to store your patient file/medical record for a period of “lifetime +6 years”. In order to meet all current medical and legal requirements in Singapore, we are not required to delete your patient file/medical record or the contents within the defined retention period.

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2. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

 

3. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

 

 

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

 

1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

 

DATA PROTECTION OFFICER

 

1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

 

Contact No.: 6425 7255 or 64249935

Email Address: eternmedical@doctor.com

 

EFFECT OF NOTICE AND CHANGES TO NOTICE

 

1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

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2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

Effective date :           19/12/2019
Last updated  :           19/12/2019

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PERSONAL DATA PROTECTION POLICY FOR JOB APPLICANTS AND EMPLOYEES

 

This Data Protection Policy (“Policy”) sets out the basis upon which Etern Medical and its related entities (the Firm”) may collect, use, disclose or otherwise process personal data of employees and job applicants in accordance with the Singapore Personal Data Protection Act (“PDPA”).

This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

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APPLICATION ON THIS POLICY
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1. This Policy applies to all persons engaged in a contract of service with us (whether on a part time, temporary, or full time basis) as interns and practice trainees working at or attached to us (collectively referred to as “employees”) as well as persons who have applied for any such position with us (“job applicants”). All references to “employment” shall apply equally to internships and practice training contracts (as may be applicable).

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PERSONAL DATA

 

2. As used in this Policy, “personal data” means data, whether true or not, about an employee or a job applicant who can be identified:

(a) from that data; or

(b) from that data and other information to which we have or are likely to have access.

 

3. If you are a job applicant, personal data which we may collect includes, without limitation, your:

(a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality and country/city of birth;

(b) mailing address, telephone numbers, email address and other contact details;

(c) résumé, educational qualifications, professional qualifications and certifications, and employment references; (d) employment and training history;

(e) work-related health issues and disabilities; and

(f) photographs.

 

4. If you are an employee, personal data which we may collect in the context of your employment with us includes, without limitation, your:

(a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality and country/city of birth;

(b) mailing address, telephone numbers, email address and other contact details;

(c) employment and training history;

(d) salary information and bank account details;

(e) details of your next-of-kin, spouse and other family members;

(f) work related health issues and disabilities;

(g) records on leave of absence from work;

(h) photographs and other audio-visual information;

(i) performance assessments and disciplinary records; and

(j) any additional information provided to us by you as a job applicant (i.e. prior to being engaged as an employee).

 

5. Generally, Company may collect personal data in various ways including:

(a) when you submit an employment application or provide documents or information such as your résumé with your employment and training history, your personal particulars which includes salary information and bank account details, photographs, details of your next-of-kin, spouse and other family members and employment references;

(b) from public information sources, search services and other third parties;

(c) when you submit your personal data to us for any other reason;

(d) CCTV recordings while you are within our premises.

The CCTV cameras are placed at strategic locations such as door entrance/exit, reception areas, common walkways and locked storage areas. In addition to security reasons, the CCTV footages will be disclosed to the management for employees’ code of conduct, disciplinary and enforcement purposes;

(e) door access logs of employees. Entrance and exit to and from the office premises is controlled by a door access system using either biometric fingerprints or access cards. In addition to security reasons, the recordings of door access logs of employees will be disclosed to the management for code of conduct, disciplinary and enforcement purposes;

(f) when you attend a seminar or other event organised by us;

(g) photographs or videos of you and/or any other accompanied persons (e.g. your family members or friends) taken by us or our representatives when you attend events hosted by us, company trips and family day events; and

(h) if you provide us with any personal data relating to a third party. By submitting such personal data to us, you also represent to us and must ensure that you have notified the third party of the terms of this Policy and obtained his consent thereto.

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6. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

 

7. We generally collect personal data that:

(a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), after:

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or

(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

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8. If you are a job applicant, your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:

(a) assessing and evaluating your suitability for employment in any current or prospective position within the organisation; and

(a) verifying your identity and the accuracy of your personal details or other information provided.

 

9. If you are an employee, your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:

(a) Performing obligations under or in connection with your contract of employment with us, including payment of remuneration and processing of income tax (Form IR8A);

(b) all administrative and human resources related matters within our Firm, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your medical insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;

(c) managing and terminating our employment relationship with you, including monitoring internet access and your use of emails to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances; (d) assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our Company;

(e) ensuring business continuity for our Company in the event that your employment with us is or will be terminated;

(f) performing obligations under or in connection with the provision of our services to our clients;

(g) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our Company, or corporate restructuring process; and

(h) facilitating our compliance with any laws, customs and regulations which may be applicable to us.

 

10. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

 

WITHDRAWING CONSENT
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11. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. If you are an employee or a job applicant, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at: eternmedical@doctor.com

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12. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within thirty (30) days from your date of notification.

 

13. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 11 above.

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14. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

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ACCESS TO AND CORRECTION OF PERSONAL DATA
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15. If you wish to make:

(a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or

(b) a correction request to correct or update any of the personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at eternmedical@doctor.com

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PROTECTION OF PERSONAL DATA

 

16. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative measure such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

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17. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secured. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

ACCURACY OF PERSONAL DATA
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18. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our General Manager in writing or via email.

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19. Employees MUST update the change of residential addresses once the change is effected on the NRIC. For Work Pass Holders, any change of personal particulars MUST be submitted to HR Department for updating the MOM WP/EP ONLINE.

 

RETENTION OF PERSONAL DATA
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20. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

 

21. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

 

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
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22. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

 

DATA PROTECTION OFFICER
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23. You may contact our Data Protection Officer at if you have any enquiries or feedback on our personal data protection policy and procedures; or if you wish to make any request.

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The Data Protection Officer

Tel No:                 6425 9935

Email Address: eternmedical@doctor.com

Address:              70 Punggol Central #01-05

                                Punggol MRT Station

                                Singapore 828868

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EFFECT OF POLICY AND CHANGES TO POLICY
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24. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data to us.

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25. We may revise this Policy from time to time without any prior notice. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.

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CONSENT FROM EMPLOYEES OR JOB APPLICANTS
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I acknowledge that I have read and understood the Company Policy and consent to the collection, use and disclosure of my personal data by the Company for the purposes set out in the Policy. I may withdraw consent for such collection, use and disclosure, and make an access or correction request in respect of my personal data, in accordance to the Company’s Policy.

 

 

Effective date :   19/12/2019
Last updated  :   19/12/2019

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