Personal Data Protection Policy relating to Cigna Europe Insurance Company S.A. - N.V. – Singapore Branch
This Policy is intended to help you understand our policies and practices with respect to personal data that the Singapore Branch we will collect, use or disclose. Cigna Singapore is committed to protecting personal data in accordance with the Personal Data Protection Act 2012 (the "PDPA" or "Act"). Please review it carefully.
Cigna Europe Insurance Company S.A.-N.V. – Singapore Branch (“Cigna”) is committed to the responsible management, use and protection of personal data of our customers and users of our systems. Any personal data processed through our systems is subject to the requirements of the PDPA.
References to “Cigna”, “we”, “us” or “our” in this Policy includes individually and collectively, all branches, subsidiaries and affiliated entities of Cigna Inc that collect, use and/or disclose personal data in Singapore and around the world.
This Policy is designed to assist you in understanding how Cigna collects, uses, discloses and/or processes the personal data you have provided to Cigna, as well as to assist you in making an informed decision before providing Cigna with any of your personal data.
“Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
The personal data processed by Cigna includes:
Cigna will collect your personal data in accordance with the PDPA. Cigna will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits Cigna to collect and process your personal data without your consent.
We collect, use and/or disclose personal data for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
We may/will need to disclose your personal data to third parties, whether sited in Singapore or outside of Singapore, for one or more of the above Purposes as well as the following purposes:
We may also disclose your personal data to third parties, without first obtaining your consent, as permitted or required by law, which may include, without limitation, the following:
The instances listed above are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at sso.agc.gov.sg/Act/PDPA2012.
In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
Sharing with Affiliates. In addition, Cigna Europe Insurance Company S.A.- N.V. Singapore branch may share personal data with Cigna Corporation and other affiliates, for one or more of the Purposes, to ensure that we are meeting our contractual obligations on a 24/7 service delivery promise and to support our operations. Please view here a list of affiliates who may access or receive personal data:
Note that personal data may be shared with recipients located in countries that provide different legal protection for personal data.
Other than for the purposes described in this Policy or as permitted by applicable law, we will obtain your written authorization to use or disclose your personal data.
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
We understand the importance of protecting your personal data. We restrict access to your personal data to authorized workforce members who need that information for legitimate purposes such as but not limited to your treatment, for payment purposes and/or for health care operations. We maintain technical, physical and administrative safeguards to ensure the privacy of your personal data.
To protect your privacy, only authorized and trained workforce members are given access to our paper and electronic records and to non-public areas where this information is stored.
Workforce members are trained on topics including:
Our corporate Privacy Office monitors how we follow the policies and procedures, and educates our organization on this important topic.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
Request for access and/or correction of personal data
You may request to access and/or correct the personal data currently in our possession or control by submitting a request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your request to us using the usual forms of communication e.g. phone and/or email.
For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
We may also charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we make a charge, we will advise you at the time you contact us and then proceed with the request once the payment is made.
For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
Notwithstanding the paragraph immediately above, we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
Request to withdraw consent in relation to your personal data
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting a request to us (refer to our contact information below).
We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us/the contract you have with us will have to be terminated.
If you, at any time, have any queries on this Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer.
You may contact our Data Protection Officer through one of the following methods:
(kindly use the word “PDPA” in the subject line)
Cigna Europe Insurance Company S.A.-N.V. – Singapore Branch
Attn: Data Protection Officer
152 Beach Road
#33-05/06 The Gateway East Singapore 189721
Fax: +65 6391 9530
Policy availability. A copy of this Policy is available for you to view, print, and/or download on www.Cigna.com.sg and click Personal Data Protection Policy.
Right to change terms of this Policy. We may change the terms of this Policy at any time, and we may, at our discretion, make the new terms effective for all of your personal data in our possession, including any personal data we created or received before we issued the new Policy.
If we change this Policy, we will update the Policy on our website and, if you are enrolled in a Cigna Global Healthcare Business plan at that time, we will send you the new Policy, as required. In addition, you can obtain a copy of the new Policy upon request when you call the International Service Centers or from our website.
You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Effective date. This Policy is effective as of 27 June 2017.
Personal Data Protection Commission Singapore:
Do Not Call (DNC) Registry: