PDPA
Southeast Asia's principles-based personal data protection regulations
EU AI Act
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.
PDPA
Personal Data Protection Act 2012 (Singapore)
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
EU AI Act
Regulation (EU) 2024/1689 Artificial Intelligence Act
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
| Aspect | PDPA | EU AI Act |
|---|---|---|
| Scope | Personal data collection, use, disclosure | AI systems by risk level (high-risk, prohibited) |
| Industry | All organizations in PDPA jurisdictions (SG, TH, TW) | All sectors using AI in EU, extraterritorial |
| Nature | Mandatory national privacy regulations | Mandatory EU regulation with conformity assessments |
| Testing | Reasonable security measures, audits | Conformity assessments, notified bodies, cybersecurity testing |
| Penalties | Fines up to SGD1M/THB5M, criminal sanctions | Fines up to 7% global turnover, market bans |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PDPA and EU AI Act
PDPA FAQ
EU AI Act FAQ
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