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Privacy Policy

1. Introduction

Diabetes Singapore (“DS”) respects your privacy and recognises the importance of the personal data you have entrusted to DS. This Data Protection Notice (“Notice”) sets out the basis on which DS may collect, use, disclose or otherwise process the personal data of its patients and service users, members, donors, volunteers and event or programme participants, in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Notice applies to personal data in DS’s possession or under its control, including personal data held by organisations DS has engaged to process personal data for DS’s purposes. 

2. Personal data

“Personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information DS has or is likely to have access to. Depending on how you interact with DS, examples of personal data DS may collect include:

  1. your name;
  2. identification numbers, such as your NRIC number (collected in full only where necessary, e.g. for health screening or tax-deductible donations);
  3. contact information such as your residential address, email address or telephone number;
  4. date of birth and gender;
  5. health information collected in the course of DS’s screening and counselling services, such as height, weight, blood pressure, HbA1c readings, and diabetic retinal photography (DRP) and diabetic foot screening (DFS) findings;
  6. photographs taken at DS events; and
  7. any other personal data you voluntarily provide for the relevant purpose.

3. Collection, use and disclosure of personal data

DS collects personal data in accordance with the PDPA. Generally, DS will notify you of the purposes for which your personal data is collected, used and/or disclosed, and obtain your consent. Where you voluntarily provide personal data to DS to receive a service – for example, when an appointment is made for you to be screened – you are deemed to consent to DS collecting and using that data for that purpose. The provision of your personal data is voluntary, but if you do not provide the personal data reasonably required, DS may not be able to provide the services requested.

Where your GP clinic or Primary Care Network arranges DS’s screening or counselling services for you, your clinic provides your particulars to DS for that purpose, and your screening results are provided back to your clinic and its network for your continued care.

If you provide DS with personal data relating to a third party, you warrant that you have informed that individual of the purposes for which DS is collecting their personal data and that they have consented to your disclosure of their personal data to DS.

4. Purposes

DS may collect, use and/or disclose your personal data for the following purposes:

  1. where you are a patient or service user – delivering screening, counselling and related services; following up with you; and reporting your results to your GP clinic and its Primary Care Network for your continued care;
  2. where you are a member – processing your membership sign-up and renewal; keeping your particulars up to date, including contacting you to verify or update them; and sending you member communications and notices;
  3. where you are a donor – processing your donation and, where applicable, submitting your donation record to IRAS for tax deduction;
  4. where you are a volunteer – screening, onboarding, deploying, communicating with and recognising you;
  5. registering you for, and evaluating, DS’s programmes, events and initiatives, and inviting you to future ones;
  6. verifying your identity;
  7. responding to and handling your queries, requests, applications, complaints and feedback;
  8. complying with applicable laws, regulations, codes of practice or guidelines, or assisting in law enforcement and investigations by any governmental and/or regulatory authority;
  9. internal compliance monitoring and audit; and
  10. any other purposes for which you have provided the information, and purposes incidental to the above.

DS may send marketing or promotional messages to your Singapore telephone number only with your consent, in line with the Do Not Call provisions of the PDPA. Service-related messages, such as appointment reminders, are not marketing messages.

DS may disclose your personal data where the disclosure is required for the purposes above – including to your GP clinic and Primary Care Network (for patients and service users), to IRAS (for tax-deductible donations), and to service providers DS has engaged, within Singapore, to perform functions for DS – where it is necessary to protect the safety or life of any individual (for example, to paramedics or medical professionals in an emergency during a screening), or where disclosure is required or permitted by law.

5. Withdrawal of consent

The consent you provide remains valid until withdrawn by you or your authorised representative in writing. Upon receiving your written request, DS may require reasonable time to process it and to notify you of the consequences of acceding to it, including any effect on the services DS can continue to provide you. In general, DS seeks to process withdrawal requests within ten (10) business days of receiving them. Withdrawing consent does not affect DS’s right to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

6. Access and correction

You may request access to and/or correction of your personal data in DS’s possession or control by writing to DS’s Data Protection Officer at the contact details below, stating your full name, contact details and the nature of your request. DS may verify your identity before acting on your request. DS will respond as soon as reasonably possible, and if DS is unable to respond within thirty (30) days, DS will inform you in writing of when it will be able to respond. If your request concerns records from screening or counselling arranged by your GP clinic or Primary Care Network, DS may refer you to your clinic, which holds your patient records for your care.

7. Protection of personal data

DS protects personal data in its possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, through appropriate administrative, physical and technical measures – including disclosing personal data internally and to authorised service providers only on a need-to-know basis, and training staff and volunteers on their data protection obligations. No method of transmission or electronic storage is completely secure; while security cannot be guaranteed, DS reviews its security measures on an ongoing basis.

8. Accuracy

To ensure your personal data is current, complete and accurate, please update DS of any changes to your personal data by informing the Data Protection Officer at the contact details below.

9. Retention

DS retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. DS ceases to retain personal data, or removes the means by which the data can be associated with you, as soon as it is reasonable to assume that

retention no longer serves the purpose for which the data was collected and is no longer necessary for legal or business purposes.

Personal data from unsuccessful job or volunteer applications is retained for no longer than one year, for the purpose of considering you for future opportunities, unless you ask DS to remove it earlier.

10. Transfers outside Singapore

DS does not transfer your personal data outside Singapore.

11. Data Protection Officer

If you have any query about this Notice or how DS manages, protects and/or processes your personal data, please contact DS’s Data Protection Officer at: enquiry@diabetes.org.sg.

12. Effect of Notice and changes to Notice

This Notice supplements but does not supersede or replace any other consent you may have previously provided to DS, nor does it affect any right DS has at law in connection with the collection, use, disclosure and/or retention of your personal data. DS may revise this Notice from time to time without prior notice; you may determine if a revision has taken place by referring to the date this Notice was last updated. Your continued use of DS’s services constitutes your acknowledgement and acceptance of such changes.

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