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What do you mean by “it is assumed that the person will not falsify or conceal the person’s identity or location.” In Regulation 3(3) of the HCS (Advertisement) Regulations?
Healthcare Services Act(Advertisement) Regulations, Application of these Regulations
It is meant to indicate that masking technology needs to be taken into consideration when determining whether an advertisement has a Singapore link. For instance, if a person uses VPN technology to enter websites which can only be accessed by non-Singapore IP addresses, and discovers “offending” advertisement in such websites, this may not come under HCSA’s scope if this advertisement was only placed in websites which cannot be accessed by Singapore IP addresses.
Related questions
How would the advertising controls affect a non-HCSA licensee who collaborates with a licensee (e.g., a medical device supplier collaborates with a medical/dental clinic) and wishes to advertise its relationship with the licensee?
Can a licensee appoint a third-party administrator (based overseas) to advertise its licensable healthcare services in other jurisdictions, i.e. promoting medical tourism?
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If a HCSA licensee places an advertisement targeted at foreigners who are not physically located in Singapore, will the advertisement be subject to HCS (Advertisement) Regulations?
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Can third parties be held liable for not complying with stipulated requirements for the advertisement of licensable healthcare services?
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