Educational · Singapore · PDPA · SMC
DNC Registry Singapore: What Clinics Must Check Before Sending SMS or Calls
Before a clinic sends a promotional SMS or call in Singapore, two questions apply: the Do Not Call Registry and the SMC's view on outreach.
- Promotional messages to Singapore numbers need a DNC check unless you hold clear and unambiguous consent in evidential form.
- A check is valid for 21 days under the PDPC's current advisory guidelines. Older 30 and 60 day figures are out of date.
- Care messages that stay informational generally fall outside the definition of a specified message.
- DNC compliance does not settle the SMC question. The Ethical Code treats unsolicited, individually addressed messages as potentially unacceptable.
- Run care messages and consented updates as two programs and keep records of consent, checks and opt outs.
Your clinic sends messages to patients all the time. Appointment reminders, test result notifications, a nudge that a health screening is due. Then one day someone suggests a promotional SMS for a new service, and the question comes up: are we allowed to send this?
It is a fair question. Clinics have phone numbers for almost every patient, and SMS is cheap, fast and read within minutes. That is exactly why the rules around it are strict.
The answer depends on what the message says, who it goes to and whether you checked the Do Not Call Registry first. For clinics there is a second question too, because the Singapore Medical Council has its own view on unsolicited outreach by doctors.
Here is how both sets of rules work, and how to keep your patient messaging on the right side of them. The short version: most care messages are fine, most promotional messages need more thought than clinics give them, and the SMC question matters as much as the registry check.
What is the DNC Registry and who has to check it?
The Do Not Call Registry is the national list that lets people in Singapore opt out of marketing messages to their phone numbers. It is established under the Personal Data Protection Act and administered by the Personal Data Protection Commission. There are three separate registers covering voice calls, text messages and fax.
The obligation to check falls on whoever sends, causes or authorises the sending of a "specified message" to a Singapore telephone number. A specified message is broadly one whose purpose is to offer, advertise or promote goods or services. That covers a clinic promoting a new treatment, and it also covers the agency or messaging vendor sending the campaign on the clinic's behalf. Outsourcing the send does not outsource the responsibility.
Before sending a specified message, the sender must check the relevant register and confirm the number is not listed, unless it holds the recipient's clear and unambiguous consent in evidential form.
How long is a DNC check valid for?
This is the point most clinics get wrong, because older material online still quotes the original figures.
The PDPC's current Do Not Call advisory guidelines set the prescribed duration at 21 days. In practice, a result that a number is not on the register can be relied on for 21 days. After that, check again before you send.
The same guidelines set a 21 day period for effecting a withdrawal of consent. If a patient tells you they no longer want promotional messages, you have up to 21 days to stop them, and the sensible approach is to action it immediately.
Some PDPC business rules documents still refer to a 30 day validity period, and early registry pages mention 60 days. Both figures reflect earlier arrangements. Work to 21 days.
Which clinic messages need a DNC check?
The test is purpose. Ask whether the message offers, advertises or promotes something.
Messages that relate purely to care the patient has already arranged generally sit outside the definition of a specified message. Appointment confirmations, reminders to collect a prescription and notices that results are ready are informational. Keep them informational and they do not need a registry check.
Messages that promote something do. A text announcing a new aesthetic treatment, a discounted health screening package, an invitation to a skin clinic open day or a reactivation message to lapsed patients are all promotional. So is a reminder that turns into a pitch halfway through.
There is also an exemption for organisations with an ongoing relationship with the recipient, where messages relate to similar or related products and services. Treat that exemption with care, and get advice before relying on it for anything promotional. For clinics, the SMC rules below often matter more than whether the DNC exemption technically applies.
What counts as clear and unambiguous consent?
Consent that the recipient actually gave for this purpose, which you can prove.
A good consent record shows that the person agreed to receive marketing messages from your clinic, on a specific channel, at that number, and when and how they agreed. A tick box on your registration form that asks "May we send you updates about our services by SMS?" and is left unticked by default is far easier to defend than a line in your terms and conditions.
Keep the consent separate from consent for care. A patient who wants appointment reminders has not necessarily agreed to promotions. Keep separate lists in your messaging software so a patient who opts out of promotions still gets their reminders.
Consent also needs to stay current. Patients change numbers, and a number that belonged to a consenting patient two years ago may now belong to someone else entirely. Build a routine for confirming contact details at each visit, and treat bounced or disputed numbers as a reason to remove them from promotional lists until the patient confirms again. Your consent record is only useful if it still matches the person on the other end of the phone.
The financial penalties for breaching the DNC provisions are set out in the Personal Data Protection Act, with a maximum of S$1 million for an organisation.
Can doctors send promotional SMS to patients at all?
This is the question that separates clinics from every other business on the registry, and it is where the Singapore Medical Council comes in.
The SMC Ethical Code and Ethical Guidelines say that the content of advertising matters more than the medium, but that some methods may be unacceptable if they are intrusive or aggressive. The examples it lists include unsolicited emails, individually addressed messages, telemarketing and active distribution of advertising materials to the public.
So a clinic can be fully compliant with the DNC rules and still send a message that raises a professional conduct question for its doctors. A registry check tells you whether you may contact a number. It does not tell you whether the message itself is appropriate.
Content rules apply too. The Ethical Code requires medical advertising to be factual, accurate and verifiable, and rules out financial inducements such as free or discounted treatments outside legitimate health promotion that is not commercial, and time limited special offers. A "20% off this week only" SMS is a problem under the Ethical Code before the DNC question even arises. Licensed healthcare institutions also sit under the MOH's advertising regulations for licensees, which aim to stop advertising that creates unrealistic expectations or encourages unnecessary use of healthcare services.
How should a clinic set up compliant patient messaging?
Build it as two programs from the start. Mixing them in one list is the root of most DNC and SMC problems we see in clinics.
- Care messages: reminders, confirmations and results notifications. Keep them informational, keep clinical detail to a minimum and send them only to patients who gave you their number for that purpose.
- Consented updates: information about services for patients who opted in, on the channel they chose. Run each list through the DNC check within 21 days of sending unless you hold clear and unambiguous consent for that channel.
- Review content against the SMC standards before anything is sent. Factual, informational, no inducements, no urgency.
- Make opting out simple and honour it straight away across all promotional channels.
- Keep records of consent, DNC check results and opt outs for as long as you keep messaging that patient.
Want a second opinion on your clinic's patient messaging? Talk to our team and we will walk through it with you.
Frequently asked questions
Do WhatsApp messages count under the DNC rules?
The DNC registers cover voice calls, text messages and fax to Singapore numbers. Whether a particular WhatsApp message is caught is a technical question worth confirming with the PDPC guidance, but the SMC content and conduct rules apply to promotional messages on any channel.
Can our clinic buy a list of phone numbers for a campaign?
Using a purchased list raises consent questions under the PDPA's data protection provisions and professional conduct questions under the SMC rules. For a clinic, the risk almost always outweighs the return.
What happens if a patient complains about a promotional SMS?
The PDPC can investigate complaints about specified messages. Your consent records and DNC check results are your evidence, so keep them organised and easy to retrieve.
Does the 21 day rule apply to email?
No. The DNC registers cover phone numbers. Email marketing is governed by separate rules, and the SMC's concerns about unsolicited messages apply to email as well.
Can we send health screening reminders to patients?
A reminder tied to a screening the patient's doctor has recommended is care related. A general promotion of a screening package to your whole database is advertising and needs the full treatment under both the DNC and SMC rules.
This article is general information only and is not legal or regulatory advice. It summarises the Do Not Call provisions of the Personal Data Protection Act 2012, the PDPC's advisory guidelines, the SMC Ethical Code and Ethical Guidelines and MOH advertising requirements as published at the time of writing, and does not address platform or carrier policies, which can impose further requirements. Regulatory guidance changes, and how it applies depends on your circumstances. Confirm your obligations with a qualified adviser before relying on any of it.
References
- Ministry of Health. (n.d.). What is the purpose of regulating the advertisement of licensable healthcare services? Ask.gov.sg. ask.gov.sg
- Personal Data Protection Act 2012 (Singapore). sso.agc.gov.sg
- Personal Data Protection Commission. (2021). Advisory guidelines on the Do Not Call provisions (revised 1 February 2021). pdpc.gov.sg
- Singapore Medical Council. (2016). SMC ethical code and ethical guidelines (2016 ed.). isomer-user-content.by.gov.sg
About the author
Dr Sandy Adel · Content Strategist, ContentClicks
Sandy is a practising dentist with a Bachelor of Dentistry from Alexandria University and over eight years of clinical experience in general dentistry. She brings that firsthand clinical knowledge directly to her writing, so the content she produces for dental and medical audiences is accurate at the clinical level before it is optimised for anything else.
Before joining ContentClicks she spent more than four years writing dental copy for practices across the Australian, US and UK markets, including two years as a dental copywriter at one of Australia's specialist healthcare marketing agencies. She writes about ethical marketing, realistic patient expectations, and the gap between what clinics promise and what biology can guarantee. More from Sandy.
