GDPR
EU regulation for personal data protection and privacy
PDPA
Singapore regulation for personal data protection.
Quick Verdict
GDPR is a comprehensive EU regulation enforcing global data protection with extraterritorial reach and hefty fines, while PDPA comprises national acts like Singapore's balancing privacy with business needs. Companies adopt GDPR for EU compliance, PDPA for regional operations.
GDPR
Regulation (EU) 2016/679 (GDPR)
Key Features
- Extraterritorial scope applies to non-EU entities targeting EU residents
- Fines up to 4% of global annual turnover for violations
- Accountability principle requires demonstrable compliance via DPIAs and records
- Enhanced data subject rights including erasure and portability
- 72-hour mandatory personal data breach notification
PDPA
Personal Data Protection Act 2012
Key Features
- Mandatory Data Protection Officer appointment
- Breach notification to PDPC within 72 hours
- Consent obligation with withdrawal mechanisms
- Cross-border data transfer limitations
- Do Not Call Registry for marketing
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GDPR Details
What It Is
Regulation (EU) 2016/679, known as GDPR, is a directly applicable EU regulation protecting natural persons' personal data. Its primary purpose is harmonizing data privacy across EU member states with global reach via extraterritorial scope. It employs a risk-based, accountability-driven approach with seven core principles: lawfulness, fairness, purpose limitation, minimization, accuracy, storage limitation, and integrity.
Key Components
- Seven principles under Article 5 govern all processing.
- **Data subject rightsaccess, rectification, erasure, portability, objection.
- Obligations include DPIAs, DPO appointment, breach notifications within 72 hours.
- Enforcement via fines up to 4% global turnover; one-stop-shop for cross-border cases.
Why Organizations Use It
Mandatory for entities processing EU data; reduces legal fragmentation, mitigates fines, builds trust. Enhances risk management, supports Digital Single Market, provides competitive edge via global benchmark status.
Implementation Overview
Involves gap analysis, policy updates, training, ROPA maintenance. Applies universally to controllers/processors; high complexity for SMEs. No certification but ongoing audits/DPA oversight; two-year transition proved challenging.
PDPA Details
What It Is
Personal Data Protection Act 2012 (PDPA) is Singapore's principal data protection regulation for private sector organizations. It governs collection, use, disclosure, and protection of personal data, balancing individual privacy rights with legitimate business needs through a principles-based approach emphasizing reasonableness and accountability.
Key Components
- Nine core **obligationsconsent, notification, access/correction, accuracy, protection, retention limitation, transfer limitation, accountability, breach notification.
- Built on PDPC advisory guidelines; no fixed control count.
- Requires Data Protection Officer (DPO) appointment and Data Protection Management Programme (DPMP).
- Compliance via self-assessment, no formal certification.
Why Organizations Use It
- Mandatory for Singapore operations handling personal data.
- Mitigates fines up to SGD 1M, enhances trust, enables data-driven innovation.
- Builds competitive edge in privacy-conscious markets.
Implementation Overview
- Phased: governance, gap analysis, controls, monitoring.
- Data mapping, policies, training, technical safeguards.
- Applies to all sizes/industries in Singapore; audits via PDPC enforcement.
Key Differences
| Aspect | GDPR | PDPA |
|---|---|---|
| Scope | Personal data processing, extraterritorial, data subject rights | Personal data collection/use/disclosure, mainly private sector |
| Industry | All sectors worldwide targeting EU individuals | Private sector organisations in specific countries (e.g. Singapore) |
| Nature | Mandatory EU regulation, directly applicable, severe enforcement | Mandatory national acts, principles-based, regulator guidance |
| Testing | DPIAs for high-risk, ongoing audits, no formal certification | Reasonable security measures, self-assessments, no mandatory DPIAs |
| Penalties | Up to 4% global turnover or €20M, administrative fines | Up to SGD1M or 10% revenue (SG), country-specific fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GDPR and PDPA
GDPR FAQ
PDPA FAQ
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