PANCARE MEDICAL
PRIVACY POLICY
1. ABOUT THIS POLICY
1.1. This is the Privacy Policy for PanCare Medical Clinic Pte. Ltd., its subsidiaries, associates, and affiliates which are listed in the Annex to this Privacy Policy (collectively, “PanCare Group”). The terms “organisation”, “we”, “us” and “our” refers to any entity of the PanCare Group, as appropriate. Although this Privacy Policy is in use across the PanCare Group, except where applicable laws provide otherwise, each entity in the PanCare Group is only responsible to you in relation to its own collection and use of your personal data, and its own actions.
1.2. We will only use your personal data where you have given us your consent or where we have another lawful basis for doing so, and in the manner set out in this Privacy Policy.
1.3. This Privacy Policy describes how we may collect, use, disclose and process your personal data when you provide us with your personal data, regardless of the medium through which such personal data was provided.
1.4. By providing us with your personal data, you acknowledge that our collection, use, disclosure and processing of your personal data will be in accordance with this Privacy Policy including, for the avoidance of doubt, the cross-jurisdictional transfer of your personal data.
1.5.This Privacy Policy supplements but does not supersede or replace any consents that you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.
1.6. If you have any feedback or issues in relation to your personal data or about this Privacy Policy or wish to make a complaint to us, you may contact our Data Protection Officer at:
Email: kp@pancare.sg
Address: 133 Ang Mo Kio Ave 3, #01-1643, Singapore 560133
When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond. This does not affect your statutory rights.
2. AMENDMENTS TO THIS PRIVACY POLICY
2.1. We may amend this Privacy Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. The updated policy will supersede earlier versions and will apply to personal data provided to us previously. The updated Privacy Policy will take effect when made available on https://pancaremedical.sg/privacy-policy/. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why or for which purposes we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email.
3. WHAT PERSONAL DATA WE COLLECT
3.1. What is personal data. “Personal data” is data that can be used to identify a natural person. What personal data we collect and process in the individual case depends on the nature of interaction with us. Examples of personal data that we collect and process include:
3.1.1. Personal identification information, including name, NRIC, passport or identification numbers, address, date of birth, contact details, email address;
3.1.2. Images of you, including CCTV images when you access and/or visit our premises and/or facilities;
3.1.3. Medical information, including your medical information, history, records, data derived from ensuing medical examinations and tests, clinical or non-clinical information about you;
3.1.4. Financial information, including credit card information;
3.1.5. Information from your interactions with our website, for example, cookies and IP addresses;
3.1.6. Employment-related information, including employment history, references, results of employment checks, and any other information of a personal nature in the context of your employment or application; and
3.1.7. Any other information of a personal nature.
3.2. Voluntary provision of personal data. We may collect personal data that you voluntarily provide to us. Please see paragraph 4 on “How We Collect Personal Data” for further details. What personal data we collect depends on the purposes for which the personal data is collected and what personal data you have chosen to provide us.
When our collection is based on consent, you can choose not to provide us with your personal data. You also have the right to withdraw your consent for us to continue collecting, using, disclosing and processing your personal data, by contacting us in accordance with paragraph 1.5. However, if you do so, it may not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you have requested or require.
3.3. Providing personal data belonging to others. In certain circumstances, you may provide us with personal data of persons other than yourself. If you do so, you represent and warrant that you have brought this Privacy Policy to his / her attention, informed him / her of the purposes for which we are collecting his / her personal data and that he / she has consented to your disclosure of his / her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, lawful use, disclosure and other processing of such personal data in accordance with the terms of this Privacy Policy.
3.4. Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.
4. HOW WE COLLECT PERSONAL DATA
4.1. Personal data collected from you. We collect personal data that is relevant to our relationship with you. We may collect personal data directly or indirectly through various channels, such as when:
4.1.1. you provide us your personal details on our website;
4.1.2. you participate in any events related to us;
If you are a patient
4.1.3. you register with us and/or submit any form to us including but not limited to registration forms and medical consent forms;
4.1.4. you visit and/or are within our premises or facilities and your images are captured by us via CCTV cameras or our security officers;
4.1.5. you are examined by our staff or medical equipment, or when you are subject to or participate in a medical examination and/or medical procedures including but not limited to various forms of screening (which may include the taking of biological samples or matter), which may result in notes, or records being made;
4.1.6. when you interact with our staff, including customer service officers, nurses, doctors, residents, allied health service professionals, and other representatives etc. via telephone calls (which may be recorded), letters, text messages (including via WhatsApp or any instant messaging application), fax, face-to-face meetings and email;
4.1.7. when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional personal data;
4.1.8. when you are contacted by, and respond to, our customer service officers, nurses, doctors, agents and other service providers;
4.1.9. when you make payment or provide details to facilitate payment, or secure or administer the application of funding / benefits / subsidies;
4.1.10. when you submit your personal data to us for any other reasons.
If you are a visitor or a volunteer
4.1.11. you register with us and/or submit any form to us including but not limited to visitor registration logs;
4.1.12. when you interact with our staff, including customer service officers, nurses, doctors, residents, allied health service professionals, and other representatives etc. via telephone calls (which may be recorded), letters, text messages (including via WhatsApp or any instant messaging application), fax, face-to-face meetings and email
4.1.13. you visit and/or are within our premises or facilities and your images are captured by us via CCTV cameras or our security officers;
If you are applying for employment
4.1.14. you submit your resume to us via our recruitment channels such as online job application portal, email, or post;
4.1.15. you complete and submit the employment application forms;
4.1.16. you attend job interview with us;
4.1.17. you undergo and complete the psychometric assessments and pre-employment medical examination; and
4.1.18. you submit any other information for the purposes of applying for a particular position
4.2. Personal data provided by others. Depending on your relationship with us, we may also collect your personal data from third party sources, for example, from:
4.2.1. any third parties whom you have authorised us to obtain your personal data from;
4.2.2. your family members or friends who provide your personal data to us on your behalf;
4.2.3. referral parties (which include other non-PanCare healthcare institutions, public agencies (including other government agencies), third party organisations, other professionals with whom you have interacted, such as medical social workers) and public sources
4.2.4. your referees, educational institutions, or previous / current employers;
4.2.5. your colleagues, supervisors, subordinates, co-workers and/or associates who provide your personal data to us directly or through third party service providers; or
4.2.6. recruitment companies and/or recruiters engaged, contracted or otherwise authorised by us.
5. WHAT WE DO WITH YOUR PERSONAL DATA
5.1. What we do. We collect, use, disclose and process your personal data where:
5.1.1. you have given us consent;
5.1.1. necessary to comply with our legal or regulatory obligations under applicable laws, such as responding to valid requests from public authorities;
5.1.1. necessary to support our legitimate business interests (please refer to paragraph 3), provided that your interests or rights do not override such interests; and
5.1.1. necessary to perform a transaction you have entered into with us or provide a service that you have requested or require from us.
5.2. General purposes. We collect, use, disclose and process your Personal Data for purposes connected or relevant to our business, and/or to manage your relationship with us. Such purposes would include:
Applicable in all instances
5.2.1. communicating with you, and responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
5.2.2. compliance with any legal or regulatory obligations, applicable laws, regulations, codes of practices, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
5.2.3. investigate any complaint, inquiry, claim or dispute or any actual or suspected illegal or unlawful conduct;
5.2.4. enforcing legal obligations owed to us, or responding to or resolving any complaints, litigation or investigations concerning us;
5.2.5. managing and engaging third parties or data processors that provide services to us,
5.2.6. any other reasonable purposes related to the aforesaid; and/or
5.2.7. other purposes that may be informed to you when your Personal Data is collected.
If you are a patient
5.2.8. managing your relationship with us, and providing medical treatment, services and advice, including management of your appointments, registration, counselling, sending notifications to you, communicating patient care issues, securing instructions on treatment choices;
5.2.9. verifying patient identity;
5.2.10. co-ordinating healthcare services provided by other healthcare providers;
5.2.11. referring / collaboration with / transferring patients to other institutions, healthcare professionals, caregivers, persons, organisations for procedures, additional support on treatment, specialist assistance, the procurement or provision of follow up care or as part of integrated / seamless / holistic care arrangements;
5.2.12. all other purposes reasonably related to the aforesaid.
If you are a visitor and/or volunteer
5.2.13. verifying your identity, visitor screening and temperature taking;
5.2.14. managing relationships with you, including contacting you on your availability to volunteer;
5.2.15. facilitating our various support programmes and events which you may participate in;
5.2.16. create a data log of your information for security monitoring and fire safety;
5.2.17. for contact tracing;
5.2.18. issuing you visitor or caregiver passes, as applicable;
5.2.19. contacting family members / next-of-kin / representatives for purposes of providing patient location (e.g. when visiting), medical updates, and seeking consent from them in emergency/incapacity situations;
5.2.20. all other purposes reasonably related to the aforesaid.
If you are applying to us for employment
5.2.21. evaluate and assess your suitability for the position applied for;
5.2.22. process your job application, including conducting interviews, background screening, employment checks, reference validations, criminal history checks and other due diligence activities which may be required under law or our risk management procedures / requirements;
5.2.23. contacting you in respect of your job application;
5.2.24. identify and evaluate you for other jobs within the PanCare Group; and/or
5.2.25. any other reasonable purposes related to the aforesaid.
Where Personal Data is used for a new purpose and where required under applicable law, we shall obtain your consent.
5.3. Legitimate business interests. We may also collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that your interests or rights do not override such interests. Our legitimate business interests include:
5.3.1. managing our business and relationship with you;
5.3.2. protecting our rights and interests, such as defending a legal claim made by, against or otherwise involving you; and
5.3.3. enforcing obligations owed to us or protecting ourselves from legal liability.
5.4. Marketing purposes. In order for us to market products, events and / or services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us or data collected from your interactions with us. However, we will not contact you to advertise or promote our products, events and / or services or send you marketing materials unless you have provided us with your consent to use your personal data for such purposes. If you do not want us to use your personal data for such purposes, you can withdraw your consent at any time by contacting us in accordance with paragraph 5.
5.5. Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes where this is required or permitted by law. Your personal data may, for example, be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or for the defence of a legal claim.
5.6. Contacting you. When we contact or send you information for the above purposes and purposes for which you have consented, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with paragraph 5.
6. USE OF COOKIES
6.1. Cookies and similar technologies. In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. We use third party cookies, which are placed by someone other than us which may gather data across multiple websites or sessions.
6.2. How we use cookies. We use cookies and other similar technologies for performance / analytics, product development purposes and to provide you customised information. These cookies collect information on how users use our website for example which pages you visit most often, whether you receive any error messages and how you arrived at our website. Information collected by these cookies is used only to improve your use of our website. These cookies are sometimes placed by third party providers of web traffic and analysis services.
6.3. Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Please note you may not be able to take advantage of all the features of our website, including certain personalised features, if you delete or refuse cookies.
6.4. Mobile Opt-out. If you access our electronic platforms through mobile devices, you can enable a “do not track” feature so as to control interest-based advertising on an iOS or Android mobile device in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalised to your interests.
7. DISCLOSURE OF PERSONAL DATA
7.1. Disclosure to related parties. We may disclose or share your personal data with other entities in the PanCare Group for the purposes described at Section 5
7.2. Disclosure to third parties. We may also disclose your personal data to third parties in connection with purposes described in Section 5, including without limitation the following circumstances:
7.2.1 third parties who provide services to us, including data processors, IT services, delivery services, job portal vendors, recruitment firms, assessment centres, medical clinics, consulting firms, financial institutions, logistic service providers, training institutes, data providers, technology providers, insurance providers, airlines, travel agencies, reservation systems and other professional services (e.g. accountants, lawyers and auditors);
7.2.2. third parties in order to fulfil any transaction as may be requested or directed by you;
7.2.3. authorities, governments, law enforcement agencies or public agencies;
7.2.4. If we are discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
7.2.5. If we are reorganised or sold, information may be transferred to a buyer who can continue to provide continued relationship with you;
7.2.6. If we are defending a legal claim your information may be transferred as required in connection with defending such claim; and/or
7.2.7. any other party if required/permitted by law.
7.3. When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
8. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
8.1. Transfers. We may transfer your personal data to different jurisdictions in connection with the purposes described in Sections 5 and 7:
8.1.1. from the jurisdiction where it is collected (which is usually where you are located) to any other jurisdictions that we operate in; and
8.1.2. to third parties in other jurisdictions.
8.2. Safeguards. We are committed to safeguarding your personal data when it is transferred across jurisdictions. We ensure that your personal data receives an adequate level of protection regardless of the jurisdiction to which it is transferred and take steps to ensure that no unauthorised or unlawful processing of your personal data is conducted other than for the purposes specified in this Privacy Policy or other lawful purposes. For example, we may enter into contracts (or impose binding rules) with recipients to protect your personal data in a manner that is consistent with all applicable laws. You may obtain details of these safeguards by contacting us in accordance with paragraph 1.5.
9. SECURITY AND RETENTION OF PERSONAL DATA
9.1. Unauthorised access. While we take reasonable precautions to safeguard your personal data in our possession or under our control, to the maximum extent permitted by applicable laws, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes.
9.2. Vulnerabilities. To the maximum extent permitted by applicable laws, we do not make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from malware, and other vulnerabilities. To the maximum extent permitted by applicable laws, we also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.
9.3. Period of retention. We keep your personal data only for so long as we need the personal data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements. How long we keep your Personal Data depends on the nature of the data, e.g., we may keep personal data for at least the duration of the limitation period for bringing claims if the data may be required to commence or defend legal proceedings. Some information may also be retained for longer, in particular where we are required to do so by law.
9.4. Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction under data protection law.
10. YOUR RIGHTS
10.1. Rights you may enjoy. You may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights may include:
10.1.1. Access: you may ask us if we hold your personal data and, if we are, you can request access to your Personal Data. This enables you to receive a copy of and information on the personal data we hold about you.
10.1.2. Correction: you may request that any incomplete or inaccurate personal data we hold about you is completed or corrected.
10.1.3. Portability: you may request to receive the data provided by you in a structured, commonly used and machine-readable format and to have such data transferred to another party, to the extent that this is technically feasible, under certain conditions.
10.1.4. Withdrawal of consent: You have the right to withdraw your consent at any time without giving reasons and with effect for the future from the date of withdrawal. The withdrawal of your consent will not affect the lawfulness of the processing of your data based on your consent before your consent was withdrawn.
10.2. If you wish to exercise any of your rights, you may contact us in accordance with paragraph 5. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.
10.3 Limitations We may be permitted under applicable laws to refuse a request, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with legal claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
Annex – List of entities within PanCare Group
PanCare Medical Clinic Pte. Ltd | 133 Ang Mo Kio Avenue 3, #01-1643, Kebun Baru Spring, Singapore 560133 | |
PanCare Medical (Yishun) Pte. Ltd. | 747 Yishun Street 72, #01-106, Nee Soon Central Green, Singapore 760747 | |
PanCare Medical (Yishun 605) Pte. Ltd. | 605 Yishun Street 61, #01-315, Nee Soon Central Meadows, Singapore 760605 | |
PanCare Medical (Serangoon) Pte. Ltd. | 3 Lorong Lew Lian, #01-70, Lew Lian Gardens, Singapore 531003 | |
PanCare Medical (Lor Ah Soo) Pte. Ltd. | 124 Hougang Avenue 1, #01-1448, Singapore 530124 | |
PanCare Medical (Lavender) Pte. Ltd. | 465 North Bridge Road, #01-5073, Singapore 191465 | |
PanCare Medical (Jurong East) Pte. Ltd. | 104 Jurong East Street 13, #01-104, Jurong East Ville, Singapore 600104 | |
PanCare Medical (Bukit Merah) Pte. Ltd. | 147 Silat Avenue, #01-32, Singapore 160147 | |
PanCare Medical (Hougang) Pte. Ltd. | 23 Hougang Avenue 3, #01-285, Hougang View, Singapore 530023 |
Last Updated: 30 Dec 2024.