Standards Comparison

    GDPR UK

    Mandatory
    2021

    UK regulation for personal data protection compliance

    VS

    MAS TRM

    Mandatory
    2021

    Singapore guidelines for financial technology risk management

    Quick Verdict

    GDPR UK mandates data protection for all UK personal data handlers with hefty fines, while MAS TRM provides supervisory tech risk guidelines for Singapore FIs emphasizing cybersecurity resilience. Organizations adopt GDPR UK for legal compliance, MAS TRM for regulatory supervision.

    Data Privacy

    GDPR UK

    UK General Data Protection Regulation

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    12-18 months

    Key Features

    • Imposes fines up to 4% worldwide annual turnover
    • Mandates accountability requiring demonstrable compliance evidence
    • Applies extra-territorially to UK-targeting non-UK entities
    • Enforces seven core data processing principles
    • Requires 72-hour ICO breach notifications
    Technology Risk Management

    MAS TRM

    Technology Risk Management Guidelines January 2021

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Board and senior management accountability for risks
    • Proportional controls by asset criticality and exposure
    • End-to-end TRM framework lifecycle management
    • Third-party risk as control environment extension
    • Annual penetration testing for internet-facing systems

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    GDPR UK Details

    What It Is

    UK General Data Protection Regulation (UK GDPR) is the UK's post-Brexit adaptation of EU GDPR, a binding legal regulation enforced by the Information Commissioner’s Office (ICO). It governs personal data processing with a risk-based, accountability-focused approach, applying to UK-established organizations and extraterritorially to those targeting UK individuals.

    Key Components

    • Seven core principles: lawfulness, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.
    • Individual rights (access, rectification, erasure, portability, objection).
    • Controller/processor obligations, DPIAs, breach notifications, lawful bases.
    • No certification; compliance via demonstrable records (RoPA), audits, ICO enforcement with fines up to 4% global turnover.

    Why Organizations Use It

    Mandated for compliance to avoid £17.5m or 4% turnover fines, enhances risk management, builds trust, supports cross-border operations. Provides strategic benefits like operational efficiency, vendor assurance, and privacy differentiation.

    Implementation Overview

    Phased: governance, data mapping (RoPA), policies/contracts, DPIAs, security, rights handling, monitoring. Applies to all sizes handling UK data; ongoing, no formal certification but ICO audits/enforcement.

    MAS TRM Details

    What It Is

    MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidance from the Monetary Authority of Singapore (MAS) for financial institutions (FIs). They establish a principles-and-outcomes-based framework to govern technology and cyber risks, promoting proportional implementation aligned to risk profile, complexity, and CIA triad (confidentiality, integrity, availability).

    Key Components

    • 15 sections spanning governance, risk frameworks, secure SDLC, IT operations, resilience, access controls, cryptography, data security, cyber operations, assessments, and audit.
    • Synthesised 12 core principles (e.g., board accountability, asset inventory, third-party oversight).
    • Defence-in-depth approach; no fixed controls, emphasizes continuous improvement.

    Why Organizations Use It

    • Critical for MAS supervisory consideration and avoiding enforcement (fines, sanctions).
    • Builds cyber resilience, operational stability, and customer trust.
    • Enables secure digital transformation; demonstrates robust risk management.

    Implementation Overview

    • Phased, risk-based: governance setup, asset inventory, controls, testing, monitoring.
    • Targets MAS-supervised FIs (banks, insurers); scalable by size/geography.
    • No formal certification; evidenced via audits, metrics, board reporting.

    Key Differences

    Scope

    GDPR UK
    Personal data processing principles, rights, security
    MAS TRM
    Technology risk governance, cybersecurity, resilience

    Industry

    GDPR UK
    All sectors handling UK personal data
    MAS TRM
    Singapore financial institutions only

    Nature

    GDPR UK
    Binding law enforced by ICO
    MAS TRM
    Supervisory guidelines considered in oversight

    Testing

    GDPR UK
    DPIAs for high-risk processing, no fixed PT
    MAS TRM
    Annual PT for internet-facing systems, DR tests

    Penalties

    GDPR UK
    £17.5M or 4% global turnover fines
    MAS TRM
    Supervisory actions, fines via other notices

    Frequently Asked Questions

    Common questions about GDPR UK and MAS TRM

    GDPR UK FAQ

    MAS TRM FAQ

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