PDPA
Singapore regulation for personal data protection
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
PDPA governs Southeast Asian data protection with principles-based obligations and fines up to SGD1m, while GDPR UK mandates comprehensive UK GDPR compliance with £17.5m/4% turnover penalties. Companies adopt PDPA regionally, GDPR UK for UK operations to ensure lawful processing and avoid enforcement.
PDPA
Personal Data Protection Act 2012
Key Features
- Mandatory Data Protection Officer appointment
- Deemed consent and notification mechanisms
- Risk-based breach notification within 72 hours
- Cross-border transfer limitation obligation
- Do Not Call Registry for marketing
GDPR UK
UK General Data Protection Regulation
Key Features
- Seven enforceable data processing principles
- Data subject rights including access and erasure
- Accountability requiring demonstrable compliance evidence
- 72-hour personal data breach notification to ICO
- Fines up to 4% of global annual 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 2012) is Singapore's principal regulation governing collection, use, disclosure, and protection of personal data by organizations. It adopts a principles-based approach balancing individual privacy rights with legitimate business needs, covering private sector entities with extraterritorial elements for data transfers.
Key Components
- Nine core obligations: consent, notification, access/correction, accuracy, protection, retention limitation, transfer limitation, accountability, Do Not Call provisions.
- Mandatory Data Protection Officer (DPO) appointment.
- Built on reasonableness and proportionality; enforced by PDPC with fines up to SGD 1 million.
Why Organizations Use It
- Legal compliance to avoid fines and enforcement.
- Enhances trust, enables data-driven innovation.
- Manages risks from breaches, transfers; supports market access.
Implementation Overview
Phased approach: governance setup, data mapping, policies, technical controls, training. Applies to all sizes in Singapore; requires DPMP, no formal certification but PDPC audits and self-assessments.
GDPR UK Details
What It Is
UK General Data Protection Regulation (UK GDPR) is the UK's post-Brexit data protection law, adapting EU GDPR with the Data Protection Act 2018. It is a binding regulation enforcing risk-based, accountability-focused personal data processing for controllers and processors in or targeting the UK.
Key Components
- **Seven core principleslawfulness, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.
- Individual rights (access, rectification, erasure, portability, objection).
- Controller/processor obligations (records, contracts, DPIAs, security).
- No fixed controls; compliance via demonstrable governance, enforced by ICO fines up to 4% global turnover.
Why Organizations Use It
- Mandatory for legal compliance, avoiding fines (£17.5M max).
- Enhances trust, reduces breach risks, enables data-driven innovation.
- Builds reputation, supports cross-border operations.
Implementation Overview
- Phased: gap analysis, ROPA mapping, policies, training, DPIAs, audits.
- Applies to all sizes handling UK personal data; ICO enforcement, no certification.
Key Differences
| Aspect | PDPA | GDPR UK |
|---|---|---|
| Scope | Personal data collection/use/disclosure in PDPA jurisdictions | Personal data processing under UK GDPR principles |
| Industry | All organisations in Singapore/Thailand/Taiwan etc. | All UK-established or targeting UK individuals |
| Nature | National principles-based statutes, mandatory | Retained EU regulation, mandatory with ICO enforcement |
| Testing | Reasonable security measures, no mandatory DPIAs | DPIAs for high-risk, regular security testing required |
| Penalties | SGD1m/THB5m fines, some criminal sanctions | £17.5m or 4% global turnover fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PDPA and GDPR UK
PDPA FAQ
GDPR UK FAQ
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