Data Protection Policy

1. Introduction

We, Singapore Institute of Advanced Medicine Holdings Pte. Ltd. (SAM Holdings), Asia Health Partners Pte. Ltd., Advanced Medicine Imaging Pte. Ltd., Proton Therapy Pte. Ltd., and Advanced Medicine Oncology Pte. Ltd. (collectively referred to as “SAM Holdings”, “we”, “us”, “our” or the “Company”), are committed to ensuring that your privacy is respected and maintained at all times.

In compliance with the Personal Data Protection Act 2012 of Singapore (“PDPA”), the Ministry of Health’s (“MOH”) guidelines and directives, and other relevant legislation, we have implemented policies, procedures and processes to protect the collection, use and disclosure of your personal data.

2. Purpose

The purpose of this policy is to explain how SAM Holdings collects, uses, processes and discloses personal data, and how you can exercise your rights in respect of your personal data.

3. What Does This Policy Cover?

This policy describes how we collect, use, store and disclose the personal data of our customers and third-party vendors.

4. Collection of Personal Data

Depending on your relationship with us, the type of information that we collect and hold may differ. In general, these relationships are classified as:

Individuals seeking health or medical treatment or services
Any individual or patient who visits our clinics, or who is referred to us through our medical service partners for medical or healthcare solutions or other services.

Customers
Any individual we work with in order to provide healthcare solutions and services.

Business entities
Any company, hospital, medical clinic, healthcare institution, medical laboratory or business organisation we work with to provide healthcare solutions and services for their business clients or customers.

Website users
Anyone who visits our website or uses our online platforms, tools or services.

Job applicants
Individuals who submit CVs to us via email, post or in response to our job recruitment advertisements. This also includes applicants who submit CVs to recruitment firms, which are subsequently forwarded to or retrieved by us.

Third-party vendors, suppliers and service providers
Any individual, not-for-profit agency or commercial organisation that enters into an agreement with us to provide products or services.

5. How We Collect Your Personal Data

5.1 At Our Medical Clinics

We collect your personal data in the following ways:

• When you register at our clinic admission counters.
• When you are referred to us by other healthcare institutions, healthcare agencies or healthcare professionals.
• When medical monitoring devices and instruments are used to diagnose or treat a specific health-related condition.
• When we seek information from medical sources, hospitals, doctors and other healthcare professionals in relation to your medical condition.
• When you are treated or attended to by our medical professionals, doctors, nurses and other clinical staff.
• When you make a payment or provide information to facilitate payment for services provided.
• When a caregiver, family member, next-of-kin or other third party provides information about you for medical treatment.
• When you communicate with our clinics via email or written correspondence.
• When you respond to our requests for additional personal data.
• When you provide feedback regarding the quality of our services.
• When you submit requests for changes or updates to your personal data, or make other requests via email or forms provided for such purposes.
• When you visit our clinics, where your image and video data may be captured through CCTV recordings.

5.2 General Collection of Personal Data

In general, we may also collect your personal data:

• When you use our services and provide details for a specific business purpose.
• When you enter into an agreement with us or provide required documentation or information relating to a transaction.
• When you interact with our sales and marketing managers, customer service officers, sales representatives or procurement services executives via telephone, email, face-to-face meetings, interviews, SMS or mail.
• When you submit documents and application forms to us during the purchase request process for our products or services.
• When you attend or provide personal data to participate in events, workshops, seminars or public forums organised by us, where your voice or image may be captured through photography, audio or video recordings.
• When you submit your CV to us via email or in response to our job recruitment advertisements.
• When you respond to our enquiries or request that we contact you.
• When you submit your CV to recruitment firms or job portals, which subsequently forward your information to us or make it available for us to retrieve.
• When you visit our website, where cookies may be used.

6. Types of Personal Data We Collect

The types of personal data we may collect about you include:

• Personal information, such as your name, NRIC, nationality, gender, date of birth and family history.
• Medical information, such as your medical conditions, allergy information, medical history and family medical history.
• Contact information, such as your mobile telephone number, landline number, residential address, email address, unit number and postal code.
• Financial information, such as bank account details, card payment details and MediSave account details.
• Photos and images, such as MRI, CT and X-ray images required for medical purposes, as well as CCTV footage.
• Job applicant information, such as work experience, educational qualifications and visa status.

7. How We Obtain Your Consent

We will inform you of the purposes for which we collect, use, disclose or store your personal data. Where applicable, we will obtain your consent in writing or through other appropriate means.

Deemed consent: When you visit our clinics to obtain healthcare services provided by us, for example, a health check-up, we may measure your blood pressure, height and weight. By proceeding with these tests, you may be deemed to have consented to the collection of your personal data where it is reasonable and necessary for us to collect such personal data to provide the specific service.

8. Withdrawal of Consent

You may withdraw or withhold consent previously given or deemed to have been given to us for the collection, use, disclosure or storage of your personal data.

If you make such a request, we will review it and inform you of the consequences of withdrawing your consent, as this may affect our ability to continue providing services to you without access to your personal data.

In certain circumstances, it may be unsafe or unlawful for us to provide healthcare services or treatment without access to personal records containing your medical history.

SAM Holdings may, in certain circumstances and where permitted or required by applicable law, be unable to give effect to a withdrawal request where doing so may affect ongoing or future medical treatment or where the continued retention, use or disclosure of the data is required by law.

9. Access, Correction and Accuracy of Personal Data

We expect you to provide personal data that is complete, accurate, true and correct.

We will take reasonable measures to ensure that the personal data we collect, use, disclose or store is accurate, complete and kept up to date.

We will make reasonable efforts to ensure the accuracy and completeness of your personal data, particularly where the data is likely to be used by us to make a decision that affects you.

10. Protection of Your Personal Data

We have implemented reasonable security controls and technical measures to protect personal data in our possession or under our control against unauthorised access.

While no security system can provide an absolute guarantee against all risks, we are committed to taking reasonable steps to protect the personal data held by us.

11. Retention of Personal Data

Your personal data will not be retained for longer than necessary to fulfil the purposes for which it was collected, unless retention is required under applicable legislation, regulations or other legal requirements.

We have implemented data retention policies and procedures to ensure that personal data is deleted or otherwise securely disposed of after a reasonable period once the purposes for retaining the data have been fulfilled.

Documents containing personal data will be disposed of or destroyed in an appropriate and secure manner when the applicable retention period has expired.

12. Transfer of Personal Data Outside Singapore

If your personal data needs to be transferred to an organisation outside Singapore, we will take appropriate steps to ensure that the transferred personal data receives a standard of protection comparable to that provided under Singapore’s PDPA.

Where appropriate, we may enter into contractual arrangements with the receiving party to ensure an appropriate standard of data protection.

13. Data Breach Notification

If we become aware of an incident or breach involving your personal data and have reasonable grounds to believe that a data breach has occurred, we will take appropriate steps to mitigate the impact of the breach.

We will assess whether the breach is notifiable under the PDPA. Where the breach is determined to be notifiable, we will notify the Personal Data Protection Commission (“PDPC”) and affected individuals in accordance with the applicable requirements and timelines under the PDPA.

14. Data Portability

Where applicable under Singapore law, you may make a request regarding personal data in our possession or under our control.

This may include personal data that you have provided to us when registering to receive healthcare services from our clinics, as well as healthcare-related data collected during your visits to our clinics.

We will process eligible requests in accordance with applicable legal requirements.

You may submit a request by:

• Email: dpo@advancedmedicine.sg
• Post: 1 Biopolis Drive, #02-01, Amnios, Singapore 138622
• In person: Visit one of our clinics and complete the relevant forms provided by our counter staff.

15. How We Demonstrate Accountability

As part of our efforts to comply with the PDPA and demonstrate accountability, we have implemented a governance structure and Data Protection Management Programme within SAM Holdings.

We have established internal and external policies and Standard Operating Procedures (“SOPs”) and provide ongoing staff awareness programmes and training.

We have also implemented processes to:

• Receive and respond to your feedback where appropriate.
• Receive suggestions or complaints to help us improve our services.
• Process requests to access or correct personal data held by us.
• Notify you where required if we experience an incident or breach involving your personal data.
• Provide choices regarding whether you wish to opt in or opt out of receiving regular updates from us.

16. Contact Our Data Protection Officer

You may contact our Data Protection Officer (“DPO”) if you have any enquiries or feedback regarding our personal data protection policies and procedures, or if you wish to make a request relating to your personal data.

Data Protection Officer
Telephone: 6708 7890
Email: dpo@advancedmedicine.sg
Address: 1 Biopolis Drive, #02-01, Amnios, Singapore 138622