PDPA Compliance Checklist for Optometry Software in Singapore
PDPA Compliance Checklist for Optometry Software in Singapore
PDPA (Personal Data Protection Act) compliance is essential when using practice management software for optometry in Singapore. Your software system stores sensitive patient data including examination records, prescriptions, and personal information. Non-compliance can result in fines up to S$1 million or 10% of annual turnover. Use this checklist to ensure your software and practices meet all PDPA requirements.
1. What is PDPA and Personal Data in Software Systems?
PDPA (Personal Data Protection Act 2012) is Singapore's data protection law. For optometry practices using software systems, this means protecting all patient data stored digitally in your practice management system, EHR, or cloud-based platforms.
What Personal Data is Stored in Your Software?
Your optometry software typically stores:
- Patient names, addresses, phone numbers, NRIC/FIN numbers
- Medical record numbers, health insurance information
- Eye examination results and test data
- Prescription information (spectacles and contact lenses)
- Diagnosis and treatment records
- Appointment history and scheduling data
- Billing and payment records
- Email addresses and communication logs
- Digital images (retinal photos, eye diagrams)
- Any other identifying health information in your system
Tip: All data stored in your practice management software, whether on-premise or cloud-based, must be protected according to PDPA regulations.
2. What are the PDPA obligations for software systems?
| Obligation | Software-Specific Requirements |
|---|---|
| Consent Obligation | Obtain consent before collecting data through software forms, online bookings, or patient portals |
| Purpose Limitation | Use software data only for disclosed purposes (patient care, billing, etc.) |
| Notification Obligation | Inform patients how their data will be used in your software system |
| Access and Correction | Allow patients to access and correct their data stored in your software |
| Accuracy Obligation | Ensure data entered into software is accurate and complete |
| Protection Obligation | Implement security measures in your software (encryption, access controls) |
| Retention Limitation | Configure software to retain data only as long as necessary |
| Transfer Limitation | Ensure adequate protection when software data is stored overseas |
| Data Breach Notification | Notify PDPC within 72 hours if software system is breached |
3. What software security features are required?
Access Control in Software
- Software requires unique user identification for each staff member
- Role-based access controls are implemented (receptionist, optometrist, admin)
- Strong password requirements enforced by software
- Automatic session timeout after inactivity
- Two-factor authentication available (if handling sensitive data)
- Account lockout after failed login attempts
Software Requirements: Each user should have unique login credentials. Software should enforce password complexity and expiration policies. Access should be limited based on job roles (e.g., receptionists shouldn't access examination notes).
Data Encryption
- Software encrypts data at rest (stored in database)
- Software encrypts data in transit (when transmitting)
- Encryption uses industry-standard methods (AES-256)
- Secure connections (HTTPS/TLS) for web-based software
- Encrypted backups of software data
Encryption Standards: Your software should use AES-256 encryption for data at rest and TLS 1.2+ for data in transit. This protects patient data even if the database is compromised.
Audit Logging in Software
- Software logs all user logins and logouts
- Software logs access to patient records
- Software logs creation, modification, and deletion of patient data
- Software logs prescription changes and examination updates
- Software logs failed access attempts
- Logs are retained for at least 6 years
- Logs cannot be deleted or modified by users
What Software Should Log: Every action in your software system should be logged - who accessed which patient record, when prescriptions were modified, when examination data was updated. This creates an audit trail for compliance.
Data Backup and Recovery
- Software has automated backup functionality
- Backups are performed regularly (daily recommended)
- Backups are stored securely (encrypted)
- Backup restoration can be tested
- Backup retention policy is defined
- Offsite backup storage is available
Backup Best Practices: Your software should automatically backup patient data daily. Backups should be encrypted and stored in a separate location. Test restoration procedures regularly.
4. What are the consent and notification requirements for software?
Consent Collection in Software
- Software allows documenting patient consent
- Consent forms can be stored digitally in patient records
- Software tracks consent withdrawal
- Consent history is maintained in patient records
- Online booking forms include consent checkboxes
Software Implementation: Your practice management software should have fields to record when and how consent was obtained. This should be linked to each patient record for easy reference.
Notification in Software Systems
- Software displays privacy notice to patients
- Patient portal includes privacy policy
- Online booking forms explain data collection purpose
- Software can generate privacy notices for patients
- Notification is clear about how data will be used
Notification Requirements: When patients use your software (online booking, patient portal, or in-clinic registration), they should be informed about how their data will be collected, used, and stored.
5. What are the access and correction rights in software?
Patient Access to Software Data
- Software allows exporting patient data in readable format
- Patient portal allows patients to view their own records
- Software can generate patient data reports
- Access requests can be fulfilled within 30 days
- Software maintains log of access requests
Software Features: Your software should allow you to export patient data (examination records, prescriptions, history) in formats like PDF or Excel. A patient portal where patients can view their own records is ideal.
Correction Rights in Software
- Software allows correction of patient data
- Correction history is maintained (audit trail)
- Software can notify relevant parties of corrections
- Corrections can be made promptly
- Software logs all correction requests
Correction Features: When patients request corrections, your software should allow you to update records while maintaining a history of what was changed and when. This creates transparency and compliance.
6. What are the data retention and disposal requirements in software?
Data Retention in Software
- Software allows configuring retention periods
- Different data types can have different retention periods
- Software can archive old records
- Retention policies are documented
- Software alerts when retention period expires
Retention Configuration: Your software should allow you to set retention periods for different types of data (e.g., examination records vs. appointment history). Software should archive rather than delete to maintain records for legal requirements.
Secure Data Disposal
- Software can permanently delete data when retention expires
- Deletion is irreversible and secure
- Software maintains deletion logs
- Data cannot be recovered after deletion
- Disposal procedures are documented
Secure Deletion: When data retention periods expire, your software should be able to permanently and securely delete data. This deletion should be logged and irreversible.
7. What are the cloud software and vendor requirements?
Cloud-Based Software Compliance
- Software vendor has executed data protection agreement with you
- Cloud data is stored in Singapore (or adequate safeguards for overseas storage)
- Software vendor is PDPA compliant
- Vendor provides security certifications (SOC 2, ISO 27001)
- Vendor has breach notification procedures
- Data residency is clearly documented
Cloud Software Checklist: If using cloud-based practice management software, ensure the vendor:
- Has data centers in Singapore or uses adequate safeguards for overseas storage
- Provides data protection agreements
- Has security certifications
- Will notify you immediately of any breaches
Software Vendor Agreements
- Data protection agreement executed with software vendor
- Agreement specifies permitted uses of data
- Agreement includes security requirements
- Agreement requires breach notification
- Agreement covers data return/destruction
- Agreement reviewed and updated regularly
Vendor Requirements: Your software vendor should sign a data protection agreement that specifies how they will protect patient data, when they can access it, and what happens in case of a breach.
8. What are the integration and third-party requirements?
Software Integrations
- All integrated systems (diagnostic equipment, labs) have data protection agreements
- Data shared with third parties is encrypted
- Integration access is logged and monitored
- Third-party access is limited to necessary data only
- Integration security is regularly reviewed
Integration Security: If your software integrates with diagnostic equipment, labs, or other third-party systems, ensure data protection agreements are in place and data transmission is secure.
API and Data Sharing
- APIs used by software are secure (authenticated, encrypted)
- Data sharing with external systems is logged
- Patient consent obtained before sharing data
- Data sharing is limited to necessary information
- Third-party systems are PDPA compliant
9. What are the mobile and remote access requirements?
Mobile App Security
- Mobile apps require authentication
- Mobile data is encrypted
- Apps can be remotely wiped if device is lost
- Mobile access is logged
- Mobile devices meet security requirements
Mobile Access: If your software has mobile apps for staff, ensure they require strong authentication, encrypt data, and can be remotely disabled if a device is lost or stolen.
Remote Access Security
- Remote access uses VPN or secure connections
- Remote access is logged and monitored
- Remote users have same security requirements
- Remote access can be revoked immediately
- Remote sessions timeout automatically
10. What are the patient portal and online booking requirements?
Patient Portal Security
- Patient portal requires secure login (username/password)
- Portal uses HTTPS encryption
- Patients can only access their own data
- Portal activity is logged
- Portal includes privacy policy
Patient Portal: If your software includes a patient portal, ensure it's secure, encrypted, and patients can only view their own records. All portal activity should be logged.
Online Booking Security
- Online booking forms are encrypted (HTTPS)
- Booking data is stored securely
- Consent is obtained during booking
- Booking data access is limited
- Booking system is regularly updated
11. What are the data breach response requirements for software?
Software Breach Detection
- Software has breach detection capabilities
- Unusual access patterns are flagged
- Failed login attempts are monitored
- System alerts for suspicious activity
- Breach detection is automated where possible
Breach Response Procedures
- Procedures for identifying software breaches
- Process to contain breach (disable access, isolate systems)
- Assessment of breach impact
- Notification to PDPC within 72 hours (if significant harm)
- Notification to affected patients
- Documentation of breach and response
Breach Response: If your software system is breached, you must:
- Contain the breach immediately
- Assess the impact
- Notify PDPC within 72 hours if significant harm
- Notify affected patients
- Document everything
12. What are the documentation and policy requirements?
Software-Specific Policies
- Data protection policy for software use
- Access control policy for software systems
- Password policy for software accounts
- Data retention policy for software data
- Breach response plan for software incidents
- Staff training on software security
Policy Requirements: Document how your practice uses software, who has access, password requirements, data retention, and breach procedures. Train all staff on these policies.
Software Configuration Documentation
- Software security settings are documented
- Access control configurations are recorded
- Backup procedures are documented
- Integration configurations are documented
- Software updates and changes are logged
13. What are common software-related violations to avoid?
| Violation | How to Avoid |
|---|---|
| Weak Software Passwords | Enforce strong password requirements in software |
| Shared User Accounts | Each staff member must have unique login credentials |
| Unencrypted Software Data | Ensure software encrypts data at rest and in transit |
| No Audit Logs | Enable comprehensive logging in software |
| Unauthorized Software Access | Implement role-based access controls |
| No Data Protection Agreement with Vendor | Execute agreements with all software vendors |
| Overseas Data Storage Without Safeguards | Ensure adequate protection for overseas cloud storage |
| No Breach Detection | Monitor software for suspicious activity |
| Inadequate Backup | Implement regular, encrypted backups |
| Patient Portal Security Gaps | Secure patient portals with encryption and access controls |
Quick Reference Checklist for Software Compliance
Must-Do Items for Software Systems
- Execute data protection agreements with software vendors
- Enable encryption in software (at rest and in transit)
- Implement unique user accounts for all staff
- Enable role-based access controls
- Activate comprehensive audit logging
- Configure automated backups
- Set up strong password requirements
- Enable automatic session timeouts
- Document software security configurations
- Train staff on software security
- Monitor software for breaches
- Review software access regularly
Conclusion
PDPA compliance for optometry software requires careful attention to how patient data is stored, accessed, and protected in your digital systems. Key takeaways:
- Choose Compliant Software - Select software vendors that are PDPA compliant and provide data protection agreements
- Enable Security Features - Activate encryption, access controls, and audit logging in your software
- Control Access - Use unique accounts and role-based access to limit who can see patient data
- Monitor Activity - Regularly review audit logs and monitor for suspicious activity
- Secure Backups - Implement regular, encrypted backups of your software data
- Train Staff - Ensure all staff understand software security and PDPA requirements
- Respond Quickly - Have procedures ready for software breaches
- Document Everything - Maintain records of software configurations, access, and incidents
Next Steps:
- Review your current software security settings
- Verify data protection agreements with vendors
- Enable all security features (encryption, logging, access controls)
- Train staff on software security
- Conduct regular security reviews
- Test backup and recovery procedures
For PDPA-compliant optometry practice management software in Singapore, CarrotByte provides built-in security features including encryption, comprehensive audit logging, role-based access controls, and secure cloud infrastructure designed for Singapore practices.
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