Privacy and Data Protection
At Rapha Radiology, our priority is the health of our patients. We endeavour to deliver our service meeting the profession’s ethical standards of quality, confidentiality, and privacy. To deserve your trust and confidence, we endeavour to protect your privacy while providing you with the best possible service and experience.
To deliver our stated services, data which we may collect or record from you include:
A. Personal Data:
o your name
o identification information such as NRIC, FIN, Passport
o contact information such as your address, email address
o telephone number
o date of birth
o marital status
o photographs and other audio-visual information
o employment information
o financial information such as credit card numbers, debit card numbers or bank account information.
B. Your Personal Health Information
i. your current medication or treatments
ii. medical history, including, where relevant, a family medical history and
iii. the name of any health service provider or medical specialist from whom you are referred
C. Details of services provided to you
D. Details of your contacts with us, including telephone records, email and online interactions.
Collection, Use And Disclosure Of Personal Data
1. We generally do not collect your personal data unless:
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after you (or your authorised representative) have been notified of the purposes for which the data is collected, as well as having consented 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).
2. We may collect and use your personal data for any or all of the following purposes:
(a) Performing obligations in the course of or in connection with our provision of the services requested by your referring doctor
(b) Verifying your identity
(c) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you
(d) Managing your relationship with us
(e) Processing payment or credit transactions
(f) Sending you information about our Group’s new developments, services, and events that we think may be of interest to you.
(g) Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
(h) Any other purposes for which you have provided the information
(i) Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(j) Any other incidental business purposes related to or in connection with the above.
3. We may disclose your personal data:
(a) Where such disclosure is required for performing obligations during or in connection with our provision of services requested by you; or
(b) To third party service providers, and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us 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 Your Consent
5. 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. 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 the contact details provided below.
6. Upon receipt of your written request to withdraw your consent, we may require reasonable time 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 your request within 25 business days of receiving it.
7. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
8. 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
9. 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.
10. 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.
11. We will respond to your request as soon as reasonably possible. 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
12. 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, 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.
13. 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.
Accuracy Of Personal Data
14. We generally rely on personal data provided by you (or your authorised representative) and will take reasonable steps to that they are accurate and complete. In order to ensure that your personal data is current and complete, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention Of Personal Data
15. We reserve the right to store your patient data file/medical record for a period of “lifetime +6 years”, in order to meet all current medical and legal requirements in Singapore.
16. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as such retention is no longer necessary for legal or medical purposes.
Data Protection Officer
20. 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:
Data Protection Officer
Rapha Radiology Pte Ltd
181 Kitchener Road, #01-14-16
New Park Shopping Arcade, Singapore 208533
Tel: 6292 8966
Effect Of Notice And Changes To Notice
21. 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.
22. 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: 1 July 2021
Last updated: 1 July 2021