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The Privacy Advisor | Global Privacy Dispatches - Singapore Related reading: Therrien calls for enforcement powers, changes in law


 By KK Lim

Electronic health records pilot successful

On February 17, Singapore General Hospital (SGH), the oldest (established in 1821) and largest acute tertiary hospital and national referral centre in Singapore, together with Singapore Telecommunica-tions Limited (SingTel), and HSA Global announced their successful pilot of the Community Care Management Solution (CCMS), an electronic health record (EHR) and management system that makes patient data available to health care providers across the island state. The use of technology is not new—Short Messaging Services (SMS) are used widely to remind patients of upcoming appointments and to provide queue status updates.
Essentially, the EHR solution has the following features:

  • the patient’s complete health information, including case notes, can be shared across the continuum of providers, including step-down providers such as polyclinics and those in community care settings;
  • healthcare providers similarly can access the information through their personal computers or PDAs to view and to update a patient’s records, as well as to share them with similar providers; and,
  • the solution is offered as a Software as a Service (SaaS) model; healthcare providers pay a monthly subscription fee to use the service.

In the future, patients will access, view, receive timely updates, and test results through an online portal. If the patient uses a monitoring device, then information such as blood glucose and weight from the device can also be uploaded to the portal, allowing healthcare providers to provide timely medical advice so as to prevent serious problems from developing.

What is unique here is that the solution is available in Singapore, where there is no specific legislation governing the privacy of personal information per se, such as Hong Kong’s Personal Data Ordinance or one pertaining to personal health information, such as the U.S. Health Insurance Portability and Accountability Act (HIPAA). Currently, personal information is protected on an industry- or sector-specific level (the banking sector for example); although there is a general code on protecting personal information—The Model Data Protection Code—based on the Organisation for Economic Co-operation and Development (OECD) guidelines. Meanwhile, the government has reportedly formed an inter-ministry committee to review the issue and to find a way to protect an individual’s personal data and addresses. at the same time as issues relating to privacy concerns, commercial requirements and other national interests.

The efforts by SGH and her partners are laudable in terms of providing better healthcare service for the patients and providers. The solution, as it stands, has raised a number of legal, security, and privacy related issues:

a) Is the patient’s consent given to the hospital on a blanket, one-time basis, therefore allowing the information to be subsequently released to a third party (a step down healthcare provider, for example), or do we need to consult the patient each time before the information is released to a potential healthcare provider? What happens when the patient changes his or her healthcare provider and what is the requirement in relation to protecting the information held by the previous healthcare provider?

b) Who will be responsible for the adverse medical situation of a patient in the event a patient or third-party healthcare provider enters erroneous information on the online portal, leading to improper treatment by an innocent third-party doctor?

c) How is security ensured across the whole continuum of those who possess the health information of the patients? What if a physician downloads a patient’s information on his or her PDA and the device is subsequently stolen?

Perhaps a Singapore version of HIPAA, or something akin to it, is needed to address the many interrelated legal, security, and privacy issues. It might be the next logical step to undergird these laudable efforts by the hospital and her providers.

KK Lim is a senior lecturer at the School of Information Technology, Nanyang Polytechnic, Singapore. He also serves on the Association of Information Security Professionals in Singapore (AiSP) and the editorial review board of The Journal of Information Privacy and Security. This article is written in his personal capacity and the author can be reached at




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