Flashcards Studio

A private cardiology clinic in Iloilo City collects patients' health information and biometric identifiers to diagnose and manage treatment. It contracts CardioPulse Ltd., a cloud analytics provider based in the United Kingdom, to process ECG traces and patient records to support clinical decisions. Intake forms authorize use of data for treatment and clinic operations but do not address disclosure to third-party processors or cross-border transfers. A data processing agreement with CardioPulse states data will be processed to provide services and will be deleted upon contract termination, but does not specify retention beyond termination or localization. Data may be stored locally and in CardioPulse's cloud in the United Kingdom. (a) Identify the lawful basis for processing the patient's health information and biometrics for diagnosis and treatment. (b) Is disclosure to CardioPulse permissible without a separate express consent? What is the controlling rule on processing sensitive personal information in this context? (c) If the data are transferred to the United Kingdom, is such cross-border transfer permissible under the Data Privacy Act, and what safeguards must be in place? Apply the rule to the facts.