We comply with the Personal Data Protection Act (Act 26 of 2012) (“PDPA”) which governs how organisations handle your Personal Information, and comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
The principles set out in this policy apply to Personal Information, including Health and Sensitive Information, you provide to us including information provided at consultations, treatments, via our web site or under any agreement or arrangement.
Key terms used in this policy are as follows:
|Personal Information||means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Personal Information as used in this policy covers Health Information and Sensitive Information.
|Health Information||means: (a) information or an opinion about:
(i) the health or a disability (at any time) of an individual; or
(ii) an individual’s expressed wishes about the future provision of health services to the individual; or
(iii) a health service provided, or to be provided, to an individual;
that is also personal information;
(b) other personal information collected to provide, or in providing, a health service to an individual
(c) other personal information collected in connection with the donation, or intended donation, by an individual of his or her body parts, organs or body substances;
(d) genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.
(a) information or an opinion about an individual’s: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record;
that is also personal information; or
(b) health information about an individual; or
(c) genetic information about an individual that is not otherwise health information; or
(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e) biometric templates.
4. Collection of Information
We collect Personal Information for the principal purpose of providing you with medical care, treatment and services, as well as for billing and administrative purposes, including submitting health fund claims on your behalf. We will also, where permitted, collect Personal Information for other related or ancillary purposes.
The types of personal information that we collect may include your name, address, telephone number, private health fund membership details, and Health Information such as your past, current, and family health conditions, test results, treatments, procedures and medical advice.
Without limiting the foregoing, we may collect Personal Information from patients that we consider to be reasonably necessary to provide health care services, including:
- medical history
- family medical history
- next of kin
- ethnic background
- current lifestyle and activities
- clinical observations
- test results
- billing information
- Concession Card numbers
- Private health insurance membership numbers and details of level of cover.
In most circumstances we will collect your Personal Information directly from you rather than third parties. But if necessary and permitted by law, we may need or be required to collect Personal Information from third parties. For example, in cases of emergency where collection of your Personal Information is necessary to prevent or lessen a serious and imminent threat to your life or health, then we may collect such information from third parties without your consent if you are physically or legally incapable of doing so.
You are not obligated to disclose your Personal Information to us. However, if you do not provide the information requested, we may not be able to provide you with the best possible health care or meet the expectations you may have of us as care providers.
In some cases, we will require you to specifically consent to any collection, use or disclosure of your Personal or Health Information as part of a Treatment Consent or Financial Consent, or other specific consent.
In most cases your consent will be requested in writing, but we may also accept your verbal consent. Sometimes your consent may also be implied through your conduct with us, or due to anticipated activities/reasons ancillary to the primary purpose of your prior consent.
Icon will destroy unsolicited information where it is determined that the information would not normally have been collected
5. Use and Disclosure of Information
We may use and disclose your Personal Information for the purpose for which it was collected, including related secondary purposes, and for other purposes authorised by you or required by law.
Examples of uses and disclosures of your Personal Information may include:
a) Use and disclosure amongst health professionals to provide treatment
Modern health care practices require a patient’s treatment to be provided by a team of health professionals. These health professionals share patient Personal Information as part of the process of providing treatment. This is managed while maintaining confidentiality and protecting the patient’s privacy in accordance with the law. Personal Information will only be disclosed to those health care professionals directly involved in a patient’s treatment. Icon may disclose Personal Information via electronic processes or standard or express post where relevant.
b) A patient’s General Practitioner or referring Medical Specialist
Icon may send a discharge summary or letter to the referring medical practitioner, nominated practitioner and/or General Practitioner following consultation or treatment. This is intended to inform the referring practitioner of information that may be relevant to any ongoing care or treatment provided by them. Icon will confirm the most up to date details of a patient’s nominated General Practitioner at the time of consultation/treatment.
c) Other health service providers
Medical practitioners or health care facilities that require access to patient health records of treatment will require an authorisation from the patient to provide a copy of the medical record to that medical practitioner or health care facility. Disclosure will be provided without consent if it is not reasonable or practicable to obtain consent and Icon reasonably believes that the disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety.
d) Students, medical, nursing, allied health disciplines
Medical, nursing and allied health disciplines undertake placements at Icon facilities. As part of their placement, students may access patient health records of treatment. All students undertaking placement with Icon sign a Confidentiality Agreement.
e) Relatives, guardian, close friends or legal representative
Icon may provide information about a patient’s condition to their parent, child, other relatives or guardians, where the patient is incapable of giving consent or cannot communicate the consent. Icon will disclose Personal Information where it is satisfied that the disclosure is necessary to provide care or treatment to the patient or for compassionate reasons, unless the patient tells Icon that they do not wish Icon to disclose their Personal Information to any such person. Where a patient does not have capacity, Icon will disclose information about the patient’s health to a person exercising that patient’s power of attorney under an enduring power of attorney or advance care directive.
f) Off-shore facilities or entities
Icon may share Personal Information to entities at other Icon Group facilities or other third parties located outside of Singapore. This may include transfer of Personal Information to Australia for medical or administrative review or support or related activities.
g) Expanded Communications
We may use your Personal Information in order to provide you with educational, clinical trials, resources, events and/or activities that we consider may be relevant or of interest to you. We do not sell your Personal Information to any marketing or other third party.
h) Other common uses and disclosures
Icon may also use and disclose Personal Information in an identified format:
- for invoicing, billing and account management;
- for health funds, or other such organisations to verify treatment provided and the financial level of cover;
- for the purposes of complying with any applicable laws, responding to a subpoena or compulsory reporting to State or Federal authorities (e.g. law enforcement or public health and safety circumstances);
- when communicating with medical defence organisations, insurers, medical experts or lawyers for anticipated or existing legal proceedings;
- if it is necessary information for the purposes of protecting a child from the risk of physical or psychological harm;
- in order to prevent or lessen a serious and imminent threat to life, health or property or a person;
- if matters are disclosed relating to serious criminal activity that have, or are likely to occur;
- to third-party service providers who manage some of the services we offer; all of whom are obligated to comply with the PDPA and the Privacy Act 1988 (Cth);
- to undertake quality assurance for the purpose of monitoring service delivery standards; and
- for the purposes of sending standard reminders (e.g. appointments or treatment reminders via text message, email, voice mail, or post to addresses disclosed to Icon).
If you request or authorise Icon to transfer your Personal Information, including your Health Information, to another health service provider, Icon will provide a copy or a written summary of such to that other health service provider as soon as practicable.
6. Access and Correction of Personal Information
In order to assist us in keeping your Personal Information accurate, complete and up to date, you are requested to promptly notify us of changes or updates to your Personal Information. You may request access to Personal Information we hold about you by making a written request to our Data Protection Officer, whose details are below. We will respond to your requests within a reasonable period.
If upon receiving access to your Personal Information, or at any other time, you believe the Personal Information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We take reasonable steps to correct your Personal Information so that it is accurate, complete and up to date.
7. Security of Personal Information
Icon stores your Personal Information in both paper and electronic forms. The security of your Personal Information is important to us. We take reasonable measures to ensure that your Personal Information is stored safely to protect it from misuse, loss, unauthorised access, modification, interference, or disclosure, and take electronic and physical security measures such as:
- Locked storage of paper records;
- Use of document shredding and security bins;
- Authentication and password controls for electronic records;
- Use of our managed devices and services (e.g. iPads, laptops, email) for transfer of Personal Information.
Icon will destroy or permanently de-identify any of your information which is in its possession or control and which is no longer needed for the purpose for which it was collected, unless otherwise required by law to be retained.
Periodic audit and risk assessments are conducted to ensure the appropriate availability, integrity and confidentiality of Personal Information managed through our systems.
In the event of a data breach, Icon will take immediate action to mitigate the breach and will comply with the mandatory data breach requirements of the Privacy Act 1988 (Cth). Icon will assess whether there is a likely risk of any serious harm to affected individuals and if so, will immediately notify such individuals with a description of the the data breach, the kinds of information concerned and recommendations about the steps that you should take in response to the data breach.
9. Do Not Call Register
The PDPA provides for the establishment of a national Do Not Call (DNC) Registry.
The DNC Registry allows individuals to register their Singapore telephone numbers to opt out of receiving marketing phone calls, mobile text messages such as SMS or MMS, and faxes from organisations.
If you have registered on (i) the No Fax Message Register; (ii) the No Text Message Register; and/or (iii) the No Voice Call Register, then Icon will not send you marketing messages of the relevant kind.
10. Enquiries and Complaints
If you have an enquiry or complaint about the way Icon handles your Personal Information then please contact our Data Protection Officer, whose contact details are in the section below. We will respond to your enquiry or complaint as soon as reasonably practicable. Making a complaint will not affect the care you receive from us, and someone else can make the complaint on your behalf.
If you are not satisfied with the result of your complaint to us, you may lodge a complaint online with the Personal Data Protection Commission at:
Or contact them at:
Personal Data Protection Commission
Address: 460 Alexandra Road #10-02 PSA Building Singapore 119963
Main Line: +65 6377 3131
Fax: +65 6273 7370
11. Contact Details
PO Box 3787
South Brisbane, QLD, 4101, Australia
Switchboard: 07 3737 4500
Fax: 07 3737 4501
What is the Personal Data Protection Act (PDPA)?
The PDPA establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of personal data. It recognises both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
The PDPA provides for the establishment of a national Do Not Call (DNC) Registry. The DNC Registry allows individuals to register their Singapore telephone numbers to opt out of receiving marketing phone calls, mobile text messages such as SMS or MMS, and faxes from organisations.
– See more at: http://www.pdpc.gov.sg/personal-data-protection-act/overview#sthash.4fSiDQ7Q.dpuf
PERSONAL DATA PROTECTION ACT 2012
(ACT 26 OF 2012)
PERSONAL DATA PROTECTION
(EXEMPTION FROM SECTION 43) ORDER 2013
In exercise of the powers conferred by section 62 of the Personal Data Protection Act 2012, the Personal Data Protection Commission, with the approval of the Minister for Communications and Information, hereby makes the following Order:
Citation and commencement
- This Order may be cited as the Personal Data Protection (Exemption from section 43) Order 2013 and shall come into operation on 2nd January 2014.Definitions
- In this Order, unless the context otherwise requires — “exempt message” means a specified fax message or a specified text message addressed to a Singapore telephone number as described in paragraph 3(1); “ongoing relationship” means a relationship, which is on an ongoing basis, between a sender and a subscriber or user of a Singapore telephone number, arising from the carrying on or conduct of a business or activity (commercial or otherwise) by the sender; “specified fax message” has the same meaning as in regulation 2 of the Personal Data Protection (Do Not Call Registry) Regulations 2013 (G.N. No. S 709/2013); “specified message” has the same meaning as in section 37 of the Act; “specified text message” has the same meaning as in regulation 2 of the Personal Data Protection (Do Not Call Registry) Regulations 2013. Exemption
- (1)Subject to the conditions specified in paragraph 4, section 43(1) of the Act shall not apply to a sender or his agent in respect of a specified fax message or a specified text message addressed to a Singapore telephone number if —(a)at the time of the transmission of the specified fax message or the specified text message to that Singapore telephone number, the sender is in an ongoing relationship with the subscriber or user of that Singapore telephone number; and (b)the purpose of the specified fax message or the specified text message is related to the subject of the ongoing relationship.
(2) Sub-paragraph (1) shall not apply if at the time of the transmission of the exempt message to that Singapore telephone number, the subscriber or user —(a)has under section 47(1) of the Act withdrawn the consent given to the sender for the sending to that Singapore telephone number of any specified message and the prescribed period under section 47(3) of the Act has expired;(b)has opted out from receiving via that Singapore telephone number any exempt message from the sender by submitting to the sender an opt-out notice referred to in paragraph 4(a) and a period of 30 days after the date on which the opt-out notice was submitted has lapsed; or(c) has otherwise indicated to the sender that he does not consent to the sender sending to that Singapore telephone number any specified message.
Conditions of exemption
- The exemption under paragraph 3(1) is subject to the following conditions:(a)an exempt message addressed to a Singapore telephone number must contain a statement, clearly displayed and in the English language, to inform the subscriber or user that he may opt out from receiving via that Singapore telephone number any exempt message from the sender in future by submitting to the sender an opt-out notice —(i)where the exempt message is a specified text message, by way of a text message to a Singapore telephone number or a short number code facility stated in the exempt message; or(ii)where the exempt message is a specified fax message, by way of a facsimile message to a facsimile number stated in the exempt message;(b)the telephone number or short number code facility referred to in sub-paragraph (a)(i) or the facsimile number referred to in sub-paragraph (a)(ii), as the case may be, must be valid and capable of receiving the opt-out notice from the subscriber or user, if any, at all times for a period of 30 days after the date on which the exempt message is transmitted by the sender or his agent; and(c)the use of the telephone number or short number code facility referred to in sub-paragraph (a)(i) or the facsimile number referred to in sub-paragraph (a)(ii), as the case may be, does not result in the subscriber or user incurring any cost additional to the cost normally incurred in sending a text message or a facsimile message.