A. AIC’s Data Protection Policy

1. As a public health care institution, the Agency for Integrated Care Pte. Ltd. (“AIC”, “we”, “us”, or “our”) collects personal data to coordinate the delivery of aged care services, and to enhance service development and capability-building across both the health and social domains.

2. This Data Protection Policy describes how we may collect, use, disclose and process your personal data when you: (a) access or use our websites, applications, and platforms (“Applications”); and/or (b) provide us with your personal data. We will only collect, use or disclose your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Data Protection Policy.

3. By voluntarily providing us with personal data, you acknowledge and agree that our collection, use, disclosure, and processing of personal data will be in accordance with this Data Protection Policy. DO NOT provide any personal data to us if you do not accept this Data Protection Policy.

4. “Personal data” is data that can be used alone or in combination with other information to identify a natural person or reflect the activity of a natural person. Examples of personal data include but is not limited to your name, address, email address, phone number and demographic information including country, age and/or sex.

5. Our Applications may contain links to other websites or platforms that are not owned or maintained by us, and whose data protection and privacy practices differ from ours. This Data Protection Policy only applies to our Applications. We are not responsible for the content and privacy practices of these other websites or platforms, and when visiting or using these third-party websites or platforms, their privacy policies apply.

B. When do we collect personal data from you?

6. We may collect your personal data through various channels, such as when you:

6.1. register for and/or attend any events organised by us, or our authorised service providers;

6.2. register and/or use any of the services provided by us or our authorised service providers;

6.3. apply for a grant or any other funding administered by us;

6.4. take part in any survey or promotional event conducted by us or our authorised service providers;

6.5. visit our Applications, register for a user account on our Applications, and/or use services and functions on our Applications;

6.6. download or use any of our mobile applications;

6.7. subscribe to our newsletters, or our mailing lists for email subscription, postal promotions or phone or other forms of marketing, including via telephone calls, messaging by SMS/ MMSs and WhatsApp;

6.8. contact us or our authorised representatives via telephone calls, letters, face to face meetings or emails;

6.9. submit a comment, question or feedback to us using our feedback forms, whether provided online or otherwise;

6.10. submit a job application to us; or

6.11. submit your personal data to us for any other reason.

7. Depending on your relationship with us, we may also collect your personal data from third party sources, including our partners (such as our business partners and service providers who provide healthcare-related services and/or social-related services to seniors and/or their caregivers), your family members or friends who provide your personal data to us on your behalf, employment and recruitment companies, employment assessment service providers, your referees, educational institutions or previous/current employers, and/or public agencies or other public sources.

8. If you provide us with any personal data belonging to and/or relating to any third party (e.g. information about your spouse, children, parents, employees etc.) for particular purposes, by submitting such information to us, you represent that you have obtained the relevant consent of any such third party to provide us with their personal data. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Data Protection Policy.

9. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are also responsible for informing us of any changes to your personal data.

C. What purposes do we collect, use and disclose your personal data for?

10. We may collect, use and disclose your personal data for any one or more of the following purposes:

10.1. communicating with you;

10.2. managing your relationship with us;

10.3. assisting you with your enquiries, and responding to your feedback, complaints and requests;

10.4. providing you with the services that you have requested. For certain services that you have requested, we may be required to upload your personal data onto any one or more of the following systems and thereafter retrieve your personal data from these systems in order to provide you with the services:

(a) IT systems and/or platforms operated or managed by third parties, including but not limited to the National Electronic Health Record system managed by the Ministry of Health; and/or

(b) IT systems and/or platforms operated or managed by AIC, including but not limited to the Integrated Referral Management System (IRMS);

10.5. verifying and processing your application for funding administered by us;

10.6. verifying and making payment to you if your application for funding administered by us is successful;

10.7. creating and managing your user account on our Applications or our mobile Applications;

10.8. keeping you updated on our events, initiatives and schemes;

10.9. informing you of available initiatives, grants or funding schemes that may be relevant to your needs;

10.10. where you are an individual seeking employment with us,

(a) administering, processing and managing your job application;

(b) evaluating your job application and suitability for employment in any prospective positions within AIC; and

(c) validating your references and conducting background screening, employment checks, criminal history checks and other due diligence activities which may be required under law or our risk management procedures;

10.11. security purposes, e.g. detecting, preventing and addressing security and technical issues related to our Applications, our mobile Applications and our services;

10.12. carrying out our legitimate interests, provided that they do not override your interests or rights, which include:

(a) managing our relationship with you, and providing services to you;

(b) complying with internal policies and procedures;

(c) protecting the rights and interests of ourselves and you; and

(d) enforcing our contractual rights, or protecting ourselves from legal liability; and

10.13. any other reasonable purposes related to the above purposes.

11. We may also collect, use or disclose your personal data for purposes connected or relevant to our business and our role as a public healthcare institution, such as:

11.1. participating in national and multi-agency efforts to:

(a) review healthcare policies and requirements;

(b) review programmes that ensure patient safety and improve the quality of healthcare services;

(c) conduct disease surveillance to address public health concerns; and/or

(d) train future generations of health and social care professionals;

11.2. sharing your personal data with the Singapore Government, Singapore Government agencies and/or public healthcare institutions, or any third parties whom we authorise (in our sole discretion) in order to serve you, for any one or more of the following purposes, unless such sharing is prohibited by law:

(a) fulfilling a legal or regulatory requirement;

(b) for delivering a public service to you; and/or

(c) where disclosure is required by any applicable law.

11.3. serving you in a more efficient and effective way;

11.4. complying with our legal obligations and requirements, or otherwise required under applicable laws;

11.5. enforcing contractual terms and conditions;

11.6. accounting, risk management, and record keeping;

11.7. performing statistical analyses and scientific research;

11.8. conducting data analytics to enable us to:

(a) identify or develop initiatives, grants or funding schemes that may be relevant to your current or future needs; and/or

(b) improve our Applications, our mobile Applications and our services so that we may provide better services to you; and/or

11.9. any other reasonable purposes related to the above purposes.

12. We may disclose your personal data to third parties in connection with the purposes described above in this Section C. We will NOT disclose your personal data to non-Government agencies and non-public healthcare institutions, except where:

12.1. they have been authorised to provide services on behalf of Government agencies or public healthcare institutions;

12.2. they are our service providers who provide us with necessary services including but not limited to IT services, hosting and maintenance services, organising of our events, accounting, data analytics services, email messaging services, delivery services, handling of payment transactions, marketing etc;

12.3. they are our consultants or professional advisers including but not limited to accountants, lawyers and auditors;

12.4. they are authorised users of public health systems operated and/or initiated by the Government of Singapore; or

12.5. you have specifically consented to such disclosure or we have other lawful basis for the disclosure.

13. You agree that we may transfer your personal data to any location outside of Singapore for the purposes set out above in this Section C. If we transfer your personal data to a country or territory outside of Singapore, we will, unless otherwise required under applicable laws, ensure that the recipient of the personal data provides a standard of protection to the transferred personal data that is comparable to the protection which your personal data enjoys under the laws of Singapore.

14. In many circumstances, we need to use and share your personal data to provide you with our services and/or fulfil our scope of engagement with you. If you do not provide us with the required personal data, or if you do not accept this Data Protection Policy or if you withdraw your consent to our use and/or disclosure of your personal data, it may not be possible for us to continue to serve you or fulfil our scope of engagement.

D. How do we respect and keep your personal data safe?

15. We are committed to safeguarding your privacy. We treat all personal data provided by you in strict confidence, and will only use your personal data in the manner set out in this Data Protection Policy. This Data Protection Policy applies to all personal data that you provide to us and the personal data we hold about you.

16. We will take reasonable steps to handle and to protect your personal data as required under the Singapore Personal Data Protection Act 2012 (PDPA) and other relevant legislations. In particular, we, as a public healthcare institution, respect and keep your personal data safe by:

16.1. limiting access of your personal data to only authorised personnel on a need-to-know basis;

16.2. conducting regular audits to ensure only authorised persons have access to your personal data;

16.3. removing details that identify you when using your personal data for internal purposes as far as possible; and/or

16.4. securing all electronic storage and transmission of your personal data with appropriate security technologies.

17. We do not make any warranty, guarantee, or representation that your use of our Applications is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. While we take reasonable precautions to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our reasonable control, such as hacking or cybercrimes.

E. Retention of Personal Data

18. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes. Some personal data may also be retained for longer, including but not limited to where we are required to do so or otherwise permitted by applicable laws.

19. You may request to withdraw your consent to our collection, use and disclosure of your personal data, exercise your rights under applicable laws (e.g. access rights or portability rights), or to update your personal data retained by us by contacting us in accordance with Clause 21. 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. However, we do not warrant that your request will be acted on as we may be permitted under applicable laws to refuse a request.

F. Changes to Data Protection Policy

20. We may amend this Data Protection Policy at any time without prior notice to you, in compliance with applicable laws or as we update our data usage and handling processes. Any changes we may make to this Data Protection Policy in the future will be posted on this website. The amended Data Protection Policy will supersede earlier versions and will apply to all personal data which you have previously provided to us.

G. Contact Us

21. Please email your request to PDPA@aic.sg if you:

21.1. wish to rectify any incorrect or out-of-date personal data previously provided to us;

21.2. intend to withdraw any consent previously given to us to collect, use and disclose any such personal data;
• Please complete this form and send it to us.

21.3. have any enquiries or feedback on our data protection policies and procedures; or

21.4. require more information on, access to or the transfer to another party of the personal data which you have earlier provided to us.
• Please complete this form and send it to us.

Last Updated On 2 May 2023

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