HOPES PRIVACY POLICY

This Privacy Policy sets out the basis which the MOH Office for Healthcare Transformation ("We", "Us", or "Our") may collect, use, disclose or otherwise process personal data of Our users in accordance with the Personal Data Protection Act 2012 including any re-enactment, supplement and amendments thereto from time to time ("PDPA"). This Notice applies to user-provided data, personal data in Our possession or under Our control, including personal data in the possession of organisations which We have engaged to collect, use, disclose or process personal data for Our purposes.

    PERSONAL DATA

  1. As used in this Notice:

    "User" means an individual who (a) has contacted Us through any means to find out more about any goods or services We provide, or (b) may, or has, entered into a contract with Us for the supply of any goods or services by Us; and

    "Personal data" means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which We have or are likely to have access.

    "User-provided data" means data about a user that is created in the course of or as a result of your use of HOPES.

  2. Depending on the nature of your interaction with Us, some examples of personal data which We may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and medical records.
  3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

    4. COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

  4. HOPES does not proactively collect any data that directly identifies you ("Personally Identifiable Information"). Upon registration on the HOPES platform, you will be given an anonymised serial number, and only your Health Provider will have knowledge of your serial number. We will not be able to identify you from this serial number.

    5. COLLECTION, USE AND DISCLOSURE OF YOUR DATA

  5. We may collect, use, disclose and retain your User-provided data and your personal data for any or all of the following purposes:
    1. performing obligations in the course of or in connection with Our provision of the HOPES service;
    2. verifying your identity;
    3. responding to, handling, and processing queries, requests, applications, complaints, feedback , and facilitating communications;
    4. managing your relationship with Us;
    5. 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;
    6. any other purposes for which you have provided the information;
    7. 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;
    8. in an aggregated or de-identified form for the purposes of improving Our systems, or for research, statistical and planning purposes;
    9. we may share your User-provided data and your personal data and other related data with other government agencies and public healthcare institutions, to enable us to provide you with better healthcare. We may also share such data with the Ministry of Health, the relevant regulatory authority for healthcare professionals, other ministries, statutory bodies and public agencies for the purpose of complying with their respective requirements, policies, and directives;
    10. security and risk management; and
    11. any other incidental purposes related to or in connection with the above.
  6. We may disclose your user-provided data:
    1. where such disclosure is required for performing obligations in the course of or in connection with Our provision of the HOPES service; or
    2. to third party service providers, agents, and other organisations including to Our Affiliates which We have engaged to perform any of the functions listed in clause 5 above for Us.
  7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with Us (for example, pursuant to a contract) 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).

    8. List of Data Collected

    Data Collected

    Explanation

    HOPES Application

    Motion Data - Pedometer, Accelerometer and Gyroscope

    Phone movement is used to determine your steps and patterns of physical activity.

    Ambient Light

    Ambient light sensors allow Us to understand the lighting conditions in your environment

    GPS Data (Obfuscated)

    GPS Data is obfuscated by adding a random displacement to your location.

    We will NOT be able to find out your exact location at any immediate point in time.

    Finger Taps

    The interval between taps will be recorded.

    We will NOT be able to identify or collect the exact location of each tap.

    App Usage

    App Usage such as usage frequency and time spent on each app category (e.g. social media, communication, games, etc)

    Power State

    We will collect data on whether the phone is turned on, and when this is so.

    Fitbit

    Sleep

    Your sleep data is derived by Fitbit which determines your time spent asleep.

    Steps

    Fitbit collects your number of steps taken

    Heart Rate

    Fitbit collects your heart rate at predefined intervals

    Heart Rate Variability

    Fitbit measures the interval between heartbeats to derive a measure of variability between beats in milliseconds

    WITHDRAWING YOUR CONSENT

  8. 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 your Care Team.
  9. Upon receipt of your written request to withdraw your consent, We may require reasonable time (depending on the complexity of the request and its impact on Our relationship with you) 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 ten (10) business days of receiving it.
  10. 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.

    11. PROTECTION OF DATA

  11. 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.
  12. 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. We shall not liable for any claims, losses, damages and expenses arising from the damage, loss or corruption to your data. We do not accept any liability for the authenticity, confidentiality, integrity, and security of any communications and other transactions made through HOPES.
  13. While HOPES takes extensive measures to obfuscate and anonymise transmitted User-provided data, given the nature of said data, We cannot guarantee that you can be identified due to the uniqueness of your User-provided data.

    14. RETENTION OF DATA

  14. We may retain your data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
  15. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

    16. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  16. We generally do not transfer your personal data to countries outside of Singapore. However, if We do so, We will obtain your consent for the transfer to be made and We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

    17. DATA PROTECTION OFFICER

  17. 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:

    18. Data Protection Officer
    Email Address: MOHT.DPO@moht.com.sg
    1 North Buona Vista Link #09-02
    Singapore 139691

    EFFECT OF NOTICE AND CHANGES TO NOTICE

  18. 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. For the avoidance of doubt, this Notice is not intended to supersede or replace any consent previously provided to us.
  19. 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 : 30 August 2024
Last updated : 30 August 2024