Singapore: "Worst Breach Of Personal Data In Singapore's History" Attracts Highest Penalties Totalling S$1 Million

Last Updated: 21 January 2019
Article by Charmian Aw
Most Popular Article in Singapore, January 2019

On 14 January 2019, Singapore's Personal Data Protection Commission issued its grounds of decision against Singapore Health Services Pte. Ltd. (SingHealth) and Integrated Health Information Systems Pte. Ltd. (IHiS) for what has been coined the "worst breach of personal data in Singapore's history".

The unprecedented cyber attack on SingHealth's patient database system led to the exfiltration of 1.5 million patients' personal data and nearly 160,000 patients' outpatient prescription records.

The commission received several complaints from members of the public regarding this data breach and commenced its investigations thereafter.

The facts of this case were as follows:

  • SingHealth is one of three healthcare clusters in the Singapore public healthcare sector. IHiS is the central national information technology (IT) agency for the public healthcare sector in Singapore.
  • SingHealth uses Sunrise Clinical Manager system (SCM), an electronic medical record software solution managed by IHiS, which is actively used by SingHealth staff in patient care and management. The SCM contains the patient medical records of over five million unique individuals, including the following types of personal data:

(a) patient particulars (name, national registration identification card numbers, address, gender, race and date of birth);

(b) clinical episode information (e.g., accident and emergency, impatient and outpatient data);

(c) laboratory, radiology, cardiology, medication and nursing orders;

(d) results of diagnostic tests and orders;

(e) clinical documentation from doctors, nurses and/or rehabilitation;

(f) vital signs, e.g., blood pressure, pulse;

(g) medical alerts and allergies;

(h) diagnosis and health issues;

(i) vaccination details;

(j) discharge summaries;

(k) medical certificates; and

(l) outpatient medication dispensed (with associated patient demographics).

  • The cyber attacker gained initial access to the SCM network in August 2017 by infecting a user's workstation, likely through an email phishing attack that led to malware and hacking tools being installed and executed on the workstation.
  • Through customized malware that infected and gained remote access to and control of other workstations between December 2017 and May 2018, the attacker gained access to a local administrator account and another service account. The attacker was then able to access and control the Citrix servers located at one of the public healthcare institutions. However, the attacker still did not have the credentials that would have enabled it to log in to the SCM database. As such, the attacker made multiple failed attempts to access it using invalid credentials. On 26 June 2018, the attacker managed to successfully obtain login credentials for the SCM database, which were then used to access the SCM database using one of the compromised Citrix servers.
  • The security incident response manager for IHiS was notified of the suspicious circumstances observed by IHiS staff. SingHealth's chief information security officer was also apprised of the events but did not make further enquiries. Neither personnel escalated the matter. As such, IHiS senior management and SingHealth's group chief information officer were only alerted to the attack on the evening of 9 July 2018.

The commission's findings were as follows:

  • Based on several policy documents including its data protection policy, IHiS is a data intermediary for SingHealth and all other healthcare institutions in the three clusters. Pursuant to section 4(3) of the Personal Data Protection Act (PDPA), an organisation that engages a data intermediary to process personal data on its behalf and for its purposes has the same obligation in respect of such data as if it had processed the data itself. Hence, both SingHealth and IHiS have an obligation to make reasonable security arrangements to protect patients' personal data in their possession or control, in accordance with section 24 of the PDPA.
  • The commission reiterated that although organisations may outsource work to vendors, the responsibility for complying with statutory obligations under the PDPA may not be delegated. In other words, SingHealth had "the primary role and responsibility of ensuring the overall protection of the personal data in its possession or under its control, even if it has engaged a data intermediary that has a duty to protect the personal data".
  • The commission stressed the importance of having a contract that sets out the obligations and responsibilities of a data intermediary to protect the organisation's personal data and the parties' respective roles, obligations and responsibilities to protect the personal data. This need for a contract was also highlighted in other jurisdictions, namely, in an information leaflet on the outsourcing of processing of personal data to data processors published by Hong Kong's privacy commission, as well as a guidance note on privacy and outsourcing for businesses by Canada's privacy commission.
  • In assessing whether each of SingHealth and IHiS had complied with their obligations under section 24 of the PDPA by making reasonable security arrangements, the commission considered the following factors as set out in its advisory guidelines on key concepts in the PDPA (revised on 27 July 2017):

(a) the nature of the personal data;

(b) the form in which the personal data had been collected (physical or electronic); and

(c) the possible impact to the individuals concerned if an unauthorised person obtained, modified or disposed of the personal data.

  • The commission determined that the SCM database contains the full medical records of all SingHealth patients, which is "very sensitive personal information". Citing its advisory guidelines for the healthcare sector (updated on 28 March 2017), the commission noted that the data is "regarded as more confidential" and "the adverse impact to individuals is significantly greater if such personal data were inadvertently accessed (e.g. relating to sensitive medical conditions)", and hence "tighter security arrangements should be employed" and it was "critical to protect the security and confidentiality of such medical records".
  • SingHealth's chief information security officer had failed to comply with the various incident response policies and standard operating procedures of the organisation. More specifically, even though he was informed of suspicious activities showing multiple failed log in attempts of the SCM, he did not escalate these security events, and this "fell far short of what a reasonable person would expect from someone in his position". The actions of SingHealth's group chief information officer and chief information security officer, and in particular, the failure to comply with standard operating procedures, was emblematic of the inadequacy of SingHealth's security arrangements and should be attributed to SingHealth itself.
  • In addition, although SingHealth had maintained oversight of IHiS's IT operations and security for the SCM through oversight and auditing mechanisms, and board and management committees, it had not taken sufficient security measures to protect the personal data in the SCM database.
  • In respect of IHiS, by its own admission, there were a number of vulnerabilities and gaps in SingHealth's network and in the IHiS systems and processes that were exploited by the attacker. In addition, the commission noted that IHiS regularly handles large volumes of sensitive personal data on behalf of public healthcare institutions in Singapore. Hence its policies and practices, and how they were implemented and enforced, were insufficient, particularly in the management of the Citrix servers.
  • Further, there were insufficient steps taken to ensure that technical measures to protect personal data were carried out as intended, and vulnerabilities that had been previously flagged to IHiS were either not remediated or not addressed in time.
  • The PDPA does not require organisations to provide an absolute guarantee for the protection of the personal data in its possession or under its control, but even so, IHiS was found not to have done what a reasonable person would consider appropriate to prevent the data breach in this case.
  • The commission found that both SingHealth and IHiS had breached section 24 of the PDPA and directed SingHealth to pay a financial penalty of S$250,000 and IHiS a financial penalty of S$750,000.

Reed Smith LLP is licensed to operate as a foreign law practice in Singapore under the name and style, Reed Smith Pte Ltd (hereafter collectively, “Reed Smith”). Where advice on Singapore law is required, we will refer the matter to and work with Reed Smith’s Formal Law Alliance partner in Singapore, Resource Law LLC, where necessary.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Similar Articles
Relevancy Powered by MondaqAI
Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Mondaq Free Registration
Gain access to Mondaq global archive of over 375,000 articles covering 200 countries with a personalised News Alert and automatic login on this device.
Mondaq News Alert (some suggested topics and region)
Select Topics
Registration (please scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions