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Singapore Addresses Confidentiality of Electronic Patient Records in New Healthcare Services Bill

Singapore’s Ministry of Health (MOH) recently drafted a new Healthcare Services (HCS) Bill aimed to bridge the gap between the country’s changing healthcare needs and technological advances.  According to the MOH, the healthcare landscape in Singapore is undergoing significant changes, including an aging population, increased chronic disease prevalence, and advancements in medicine and health technologies.  The HCS Bill will “better safeguard the safety and well-being of patients, while enabling new and innovative services that benefit patients to be developed, in the changing healthcare environment.”

Currently, healthcare providers in Singapore are licensed and regulated under the Private Hospitals and Medical Clinics Act (PHMCA), which was designed to protect patient safety through the licensing of physical healthcare premises.  But, brick and mortar locations are quickly becoming a thing of the past as more and more healthcare services are delivered through mobile and online channels.  MOH intends to respond to this shift by repealing the PHMCA and replacing it with this new HCS Bill.


One of the key provisions of the HCS Bill addresses the confidentiality of patient records, namely the National Electronic Health Records (“NEHR”).  This provision states that “[t]he NEHR can be accessed only for purposes of patient care, and not for other purposes, including assessment for employment and insurance.”  The Bill further emphasizes that certain measures, including the provision of access logs, regular audits, and penalties that are “aligned with comparable offences under other recently enacted legislations,” will be implemented to discourage and safeguard against any unlawful access to the NEHR.

Owned by the MOH and managed by the Integrated Health Information Systems, Singapore’s NEHR is a universal system that receives, consolidates, and maintains patient health records across different healthcare providers.  The NEHR receives different types of information from healthcare institutions and national registries, including admission and visit history, hospital discharge summaries, lab results, medication history, and documentation of immunizations.  Singaporeans are automatically included in the NEHR, but they may opt out of the program at any time.

Singapore’s Ministry of Health is inviting feedback on the draft HCS Bill until February 15, 2018.

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About this Author

Yodi Hailemariam, Drinker Biddle Law Firm, Washington DC, Cybersecurity Law Attorney

Yodi S. Hailemariam focuses her practice on U.S. and cross-border information governance, data privacy, cybersecurity, electronic discovery, legal analytics and the Internet of Things. Yodi has experience in a wide range of industries, including health care, pharmaceuticals and life sciences, intellectual property, insurance and financial services.

A frequent author, speaker and panelist on “all things data,” Yodi advises companies regarding electronic discovery in complex civil litigations, white collar defense, and corporate...