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Question
A private hospital in Cebu City collects patients’ health information and iris biometric data to diagnose and treat. It contracts a cloud analytics provider based in Singapore to process imaging and biometric data to support clinical decisions. Intake forms authorize use of data for treatment and hospital operations but do not address disclosures to third-party processors or cross-border transfers. A data processing agreement with the Singapore provider states that 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 on local servers and in the provider’s cloud in Singapore. (a) Identify the lawful basis for processing the patient’s health information and biometric data for diagnosis and treatment. (b) Is disclosure to the Singapore-based processor 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 Singapore, is such cross-border transfer permissible under the Data Privacy Act, and what safeguards must be in place? Apply the rule to the facts.