PDPA
Singapore regulation for personal data protection
APRA CPS 234
Australian prudential standard for information security resilience
Quick Verdict
PDPA governs personal data protection across Singapore, Thailand, Taiwan for all organizations, emphasizing consent and rights. APRA CPS 234 mandates information security resilience for Australian financial entities, requiring board oversight and testing. Companies adopt PDPA for privacy compliance, CPS 234 for prudential cyber resilience.
PDPA
Personal Data Protection Act 2012
Key Features
- Mandatory Data Protection Officer appointment
- Consent with deemed consent exceptions
- 72-hour breach notification obligation
- Transfer Limitation for cross-border flows
- Do Not Call Registry for marketing
APRA CPS 234
APRA Prudential Standard CPS 234 Information Security
Key Features
- Board ultimate responsibility for information security
- 72-hour APRA notification for material incidents
- Systematic risk-based testing of controls
- Third-party managed assets fully in scope
- Asset classification by criticality and sensitivity
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
PDPA Details
What It Is
Personal Data Protection Act 2012 (PDPA) is Singapore's principal privacy regulation for private sector organizations. It governs collection, use, disclosure of personal data through a principles-based, risk-proportionate framework balancing individual rights and business needs.
Key Components
- Nine core obligations: Consent/Notification, Access/Correction, Accuracy, Protection, Retention Limitation, Transfer Limitation, Accountability, Breach Notification (Part 6A), Do Not Call.
- Mandatory DPO appointment and Data Protection Management Programme (DPMP).
- Built on reasonableness and accountability principles; no fixed control count.
- Compliance via self-assessment, PDPC guidance/enforcement.
Why Organizations Use It
- Mandatory for Singapore organizations handling personal data; fines up to SGD 1 million.
- Mitigates breach risks, builds customer trust, enables compliant data use.
- Strategic edge in digital economy, partnerships, reputation.
Implementation Overview
- Phased: governance/DPO, data mapping/DPIAs, policies/controls/training, monitoring/audits.
- Applies to all private sector sizes/industries; PDPC oversight, no certification.
APRA CPS 234 Details
What It Is
APRA Prudential Standard CPS 234 (Information Security) is a binding regulation issued by the Australian Prudential Regulation Authority. Effective from 1 July 2019, it mandates APRA-regulated financial entities to maintain information security capabilities commensurate with threats and vulnerabilities. Its risk-based approach emphasizes governance, controls, testing, and rapid incident reporting to protect confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties.
Key Components
- 11 core requirements spanning board accountability, role definitions, policy frameworks, asset classification, lifecycle controls, incident response, systematic testing, internal audit assurance, and APRA notifications (72 hours for material incidents, 10 business days for control weaknesses).
- Built on CIA triad principles with commensurability to risks; no fixed controls but assurance-driven model.
- Compliance via evidence of testing and remediation, no formal certification.
Why Organizations Use It
- Mandatory for APRA entities (banks, insurers, super funds) to avoid penalties, heightened supervision.
- Enhances cyber resilience, third-party oversight, stakeholder trust; reduces incident impacts on operations and customers.
Implementation Overview
- Phased: gap analysis, governance setup, asset inventory, controls/testing, continuous monitoring.
- Applies to all sizes in Australian finance; requires independent audits and board oversight. (178 words)
Key Differences
| Aspect | PDPA | APRA CPS 234 |
|---|---|---|
| Scope | Personal data protection, processing, rights | Information security, cyber resilience, CIA triad |
| Industry | All organizations in Singapore/Thailand/Taiwan | Australian financial services (banks, insurers) |
| Nature | Mandatory privacy acts, administrative fines | Mandatory prudential standard, supervisory actions |
| Testing | Security measures, no mandated testing frequency | Systematic independent testing, annual reviews |
| Penalties | SGD 1M fines, THB 5M administrative | Enforcement notices, remediation orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PDPA and APRA CPS 234
PDPA FAQ
APRA CPS 234 FAQ
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