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Singapore Government Introduces Bill on Use of Personal Data collected by Digital Contact Tracing Tools

According to Smart Nation Singapore, to date, more than 80% of the population have either downloaded the TT App or collected the TT Token. TT, together with other digital contact tracing tools, has shortened the average time required for contact tracing from 4 days to less than 1.5 days.

For contact tracing to be carried out effectively, the government have continued to require the strong support and active usage of the TT App or Token, to keep Singapore safe.

COVID-19 Bill introduced under extraordinary circumstances

On 1 February, the Government moved the COVID-19 (Temporary Measures) (Amendment) Bill in Parliament under a Certificate of Urgency. The Government is introducing this Bill under extraordinary circumstances. The legislation is intended to remove any doubt about what personal contact tracing data can be used for.

These amendments will give legal force to the statement made in Parliament by Minister-in-Charge of the Smart Nation Initiative, Dr Vivian Balakrishnan, and Minister for Home Affairs and for Law, Mr K Shanmugam on 5 January, that the use of TraceTogether (TT) data in criminal investigations would be restricted to serious offences.

Use of Personal Data collected by Digital Contact Tracing Tools

The Bill will cover the usage of personal contact tracing data recorded in digital contact tracing systems – personal contact tracing data. These systems include TT and SafeEntry (SE), as well as BluePass (BP). The TT Programme, which includes the TT App and the TT Token, collects proximity data to help identify close contacts.

SE is the national check-in system that is a digital equivalent of visitor record logs. BP is a contact tracing system developed by the private sector that can interoperate with TT.

The legislative amendments will specify that public sector agencies can use personal contact tracing data recorded in digital contact tracing systems only for the purpose of contact tracing, except where there is a need for police officers and law enforcement officers to use the data for criminal investigations and proceedings in respect of serious offences.

These restrictions on the Government’s use of personal contact tracing data will apply regardless of any other written law stating otherwise.

Any public officer or contractor engaged by a public sector agency found guilty of unauthorised use or disclosure of personal contact tracing data can be fined up to $20,000, or sentenced to imprisonment for up to 2 years, or both.

The legislation applies to personal contact tracing data – data which identifies an individual. It does not prohibit de-identified, aggregated or anonymised data recorded in the digital contact tracing systems from being used in research to strengthen public health response, or to monitor the effectiveness of safe management measures implemented by businesses.

Once the pandemic is over, the Government has said that it will stop the use of the TT and SE systems. Public agencies must also then stop collecting such data, and delete the collected personal contact tracing data as soon as possible.

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