Standards Comparison

    PDPA

    Mandatory
    2012

    Southeast Asia's principles-based personal data protection regulations

    VS

    EU AI Act

    Mandatory
    2024

    EU regulation for risk-based AI safety and governance

    Quick Verdict

    PDPA governs personal data protection across Asian jurisdictions with consent and security rules, while EU AI Act regulates AI systems risk-based with conformity assessments. Companies adopt PDPA for regional privacy compliance, AI Act for EU market access and safety.

    Data Privacy

    PDPA

    Personal Data Protection Act 2012 (Singapore)

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

    Key Features

    • Principles-based framework balancing privacy and business needs
    • Mandatory 72-hour data breach notification regime
    • Explicit consent required for sensitive personal data
    • Do Not Call Registry for direct marketing controls
    • Risk-based cross-border transfer safeguards and exemptions
    Artificial Intelligence

    EU AI Act

    Regulation (EU) 2024/1689 Artificial Intelligence Act

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • Risk-based four-tier AI classification framework
    • Prohibitions on unacceptable-risk AI practices
    • High-risk conformity assessments and CE marking
    • GPAI model transparency and systemic risk duties
    • Tiered fines up to 7% global turnover

    Detailed Analysis

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

    PDPA Details

    What It Is

    PDPA (Personal Data Protection Act) refers to a family of statutes, prominently Singapore's PDPA 2012, Thailand's PDPA 2019, and Taiwan's PDPA. These are mandatory regulations governing collection, use, disclosure, and protection of personal data by organizations. Primary purpose: balance individual privacy rights with legitimate business needs via principles-based approach including consent, notification, and accountability.

    Key Components

    • Core obligations: consent/exception bases, purpose limitation, data subject rights (access, correction), security safeguards, breach notification, transfer controls, accountability (DPO appointment).
    • Built on GDPR-influenced principles with local nuances like deemed consent and Do Not Call Registry.
    • No fixed control count; compliance via policies, DPIAs, and DPMP.

    Why Organizations Use It

    • Legal compliance to avoid fines (up to SGD 1M, THB 5M).
    • Risk reduction via breach readiness and vendor governance.
    • Builds trust, enables cross-border operations, supports innovation with privacy-by-design.

    Implementation Overview

    • Phased: governance/DPO setup, data mapping/DPIAs, policy/controls rollout, training/audits.
    • Applies to private sector organizations processing local data; extraterritorial in Thailand.
    • No certification; PDPC/PDPC enforcement via audits, penalties.

    EU AI Act Details

    What It Is

    EU AI Act (Regulation (EU) 2024/1689) is a comprehensive EU regulation establishing harmonized rules for artificial intelligence. It adopts a risk-based approach, prohibiting unacceptable-risk practices, regulating high-risk systems, imposing transparency on limited-risk AI, and minimally regulating others. Scope covers providers, deployers, and value-chain actors for AI systems used in the EU.

    Key Components

    • Prohibited practices (Article 5), high-risk requirements (Articles 9-15: risk management, data governance, documentation, oversight, cybersecurity).
    • GPAI obligations (Chapter V), conformity assessments, CE marking, EU database registration.
    • Built on product-safety principles; up to 7% global turnover fines.

    Why Organizations Use It

    Mandatory for EU market access; mitigates legal risks, fines, bans. Enhances trust, competitiveness in high-stakes sectors like employment, biometrics. Builds robust AI governance, aligning with GDPR/NIS2.

    Implementation Overview

    Phased rollout (6-36 months); inventory/classify AI, build RMS/QMS, conformity assessments. Applies to all sizes in EU-impacting sectors; involves audits, notified bodies for high-risk.

    Key Differences

    Scope

    PDPA
    Personal data collection, use, disclosure
    EU AI Act
    AI systems by risk level (high-risk, prohibited)

    Industry

    PDPA
    All organizations in PDPA jurisdictions (SG, TH, TW)
    EU AI Act
    All sectors using AI in EU, extraterritorial

    Nature

    PDPA
    Mandatory national privacy regulations
    EU AI Act
    Mandatory EU regulation with conformity assessments

    Testing

    PDPA
    Reasonable security measures, audits
    EU AI Act
    Conformity assessments, notified bodies, cybersecurity testing

    Penalties

    PDPA
    Fines up to SGD1M/THB5M, criminal sanctions
    EU AI Act
    Fines up to 7% global turnover, market bans

    Frequently Asked Questions

    Common questions about PDPA and EU AI Act

    PDPA FAQ

    EU AI Act FAQ

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