1. Commitment To Privacy
At THE SYNERGY COLLECTIVE (the “Practice”, “Us” or “We”), our principal concern is, and always will be, the health of clients who engage our practice. A high level of trust and confidentiality is required to ensure the confidence of the clients we serve.
2. What Is Client Information
Client information means identifying information about an individual relating to their physical or mental health. The personal data collected will generally include but not limited to the following:
the client’s name, contact number, email address;
current treatments used by the client;
previous/current treatment/medical history, including, where relevant, a family treatment/medical history; and
the name of any social service provider, health service provider or medical specialist to whom the patient is referred.
3. Why We Collect Information
We ask you for information to establish a relationship to serve your mental health requirements. We obtain most of our information about you directly from you, or from other mental health and social service practitioners whom you have seen and authorised to disclose to us. We will limit the information we collect to only what is needed. We will obtain your consent if we wish to use your information for any other purpose.
3.1 General Purposes
In using our services and providing us with your personal data, you hereby agree that the Practice may collect, store, process, disclose, access, review and/or use personal data (including sensitive personal data) about you, whether obtained from you or from other sources, for the purposes set out below and/or any other administrative or operational purposes and/or the purpose of managing your relationship as a client with the Practice or any other company within the Practice:
providing services to you and meeting your emotional and healthcare needs within THE SYNERGY COLLECTIVE;
to avail the services which the Practice provides, pathology providers, or other allied health professionals such as psychologists, counsellors and social workers;
where there is a serious and imminent threat to an individual’s life, health, or safety;
where there is a serious threat to public health or public safety;
resolving complaints and dealing with enquiries made by you;
maintenance and updating of the data;
administrative or operational purposes;
processing credit notes and processing refunds;
collection of fees, charges and expenses for service provided;
verification and identification purposes;
collecting payments by bank transfers or other means;
carrying out billing, accounting, auditing and the maintenance of proper book-keeping for the Practice’s operations and business;
the disclosure of the relevant books, documents, records and information (in hard or soft copy) to the auditors for the preparation of financial reports; and/or
compliance with the applicable laws and regulations.
3.2 Marketing Purposes
Where you have agreed by signing/completing the Practice’s Registration Form for our marketing communications (ie: updating of our products and services) by providing the Practice with your Singapore telephone number or email address and have indicated to us that you consent to receive marketing communications via these channels. The Practice may contact you from time to time, whether by SMS, whatsapp, email or otherwise, to inform you about our new developments, services and events that we think may be of interest to you.
Should you choose not to receive any marketing communications from us, the Practice will not send you purely marketing messages and will not share your personal data with other unauthorised third parties. Please note that the Practice may still contact you for research or administrative purposes, such as service-related notices.
3.3 Optional Purposes
From time to time, you may register for additional services that the Practice provides. The purpose that your personal data will be collected, used or disclosed will be noticed to you at the time of your registration for these services.
4.1 Consent Required
Your consent is important to us. We will not collect, use or disclose your personal data unless:
you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
the collection, use or disclosure of your personal data without your consent is required or authorized under the PDPA or other written law.
4.2 Provision of Consent
We will not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data.
4.3 Consent of Third Parties
If you have provided the Practice with any personal data relating to any other individuals, you warrant that you have obtained the necessary consents of the individuals.
4.4 Withdrawal of Consent
4.4.2 Please be aware that once we receive confirmation that you wish to withdraw your consent to receiving marketing communications, it may take up to thirty (30) working days for your withdrawal to be reflected in our systems. During this period of time, you may still receive marketing communications from us.
4.4.3 On receipt of such notice, the Practice will inform you of the likely consequences of withdrawing your consent. Depending on the nature of the withdrawal of consent, we may no longer be in a position to continue to provide our services to you. Such a withdrawal may, therefore, result in the termination of any doctor-patient relationship that you may have with us.
5. Data Quality
We will take reasonable steps to make sure that the personal data we collect, use or disclose is accurate, complete and up to date.
We endeavour to ensure that all decisions involving your personal data are based on the accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all relevant information and to inform us of any significant changes.
While all reasonable efforts will be made to keep your personal data accurate, you are kindly requested to disclose all relevant information, inform us of any change and to ensure that all your personal data that is submitted to us is current, complete, accurate, true and correct.
7. Safeguards: Protecting Your Information
The Practice maintains personal data in the format of electronic files. We will protect your personal data with appropriate safeguards and security measures to prevent misuse, loss and unauthorized access, modification and disclosure.
Access to personal data will be authorised only for the mental health / counselling professionals and employees associated with the Practice, other agents who require access in the performance of their duties, and to those otherwise authorised by law. We provide personal data to healthcare and social service providers acting on your behalf, on the understanding that they are also bound by law and ethics to safeguard your privacy.
Our computer systems are password-secured and constructed in such a way that only authorised individuals can access secure systems and databases
We will not keep personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal information if it is no longer required.
8. Access and Correction
You are entitled to have access to the personal data about you that is in the possession or under the control of the Practice and information about the ways in which the personal data has been or may have been used or disclosed within a year before the date of the request. This can be done by you making a written application to the Designated Person (as stated below) requesting for any such information. We may charge you a fee (representing our costs in administering your request) for supplying such information and reserve the right to refuse requests which, in our opinion, occur with unreasonable frequency.
We will also, where you have requested that we correct an error or omission in the personal data about you that is kept with us, correct such data as soon as practicable and send the corrected personal data to every organisation to which the personal data was sent before it had been corrected, if applicable, unless that organisation does not need the corrected personal data for any legal or business purpose.
We may, however, choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:
We are satisfied on reasonable grounds that the correction should not be made;
The request for access is frivolous or vexatious or the information requested is trivia;
The personal data is related to a prosecution and all the proceedings related to the prosecution have not been completed;
The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position; and
The personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed.
Please also note that we are not required to correct information relating to clinical observations opinions made in good faith.
10. Enquiries & Requests
We have designated the person (“Designated Person”) who will be responsible for ensuring the Practice’s compliance with applicable data protection laws. If you have any queries or requests or wish to make any applications concerning your personal information or data, please contact the Designated Person using the details provided below:
Data Protection Officer, THE SYNERGY COLLECTIVE