PDPA
Singapore regulation governing personal data in private sector
GLBA
U.S. regulation for financial privacy and data safeguards
Quick Verdict
PDPA governs personal data protection across Singapore's private sector with consent and DPIA requirements, while GLBA mandates privacy notices and security programs for US financial institutions handling NPI. Organizations adopt PDPA for regional compliance, GLBA to meet federal financial privacy laws.
PDPA
Personal Data Protection Act 2012
Key Features
- 1. Mandatory competent DPO appointment with senior reporting
- 2. Structured Data Protection Management Programme (DPMP)
- 3. Deemed consent mechanisms for business purposes
- 4. Mandatory breach notification for significant harm
- 5. Flexible cross-border transfer safeguards via APEC CBPR
GLBA
Gramm-Leach-Bliley Act (GLBA)
Key Features
- Mandates privacy notices and opt-out for NPI sharing
- Requires written information security program with safeguards
- Designates Qualified Individual for program oversight
- Imposes 30-day FTC breach notification for 500+ consumers
- Enforces service provider oversight and risk assessments
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 legislation regulating collection, use, disclosure, and protection of personal data by private sector organizations. It adopts a principles-based, risk-based approach emphasizing accountability through a Data Protection Management Programme (DPMP) with four steps: governance, policy, processes, and maintenance.
Key Components
- Nine core obligations: consent, notification, access/correction, accuracy, protection, retention limitation, transfer limitation, accountability, breach notification.
- Mandatory DPO appointment and DPMP framework.
- Built on international norms like GDPR but with local nuances (deemed consent, DNC registry).
- Compliance via self-assessment (PATO) and enforcement up to SGD 1M fines.
Why Organizations Use It
- Mandatory compliance for Singapore operations to avoid fines (up to 10% global revenue).
- Enhances trust, enables data-driven innovation, reduces breach risks.
- Supports partnerships via demonstrated safeguards; mitigates vendor/third-party exposures.
Implementation Overview
- Phased: baseline assessment, data mapping/DPIAs, policies/technical controls (encryption, RBAC), training, audits.
- Applies to all private sector entities handling personal data; scalable for SMEs via tools like OneTrust.
- No certification but requires ongoing audits, breach exercises, board reporting.
GLBA Details
What It Is
The Gramm-Leach-Bliley Act (GLBA), enacted in 1999, is a U.S. federal regulation modernizing financial services while mandating consumer financial privacy protections. It targets nonpublic personal information (NPI) handled by financial institutions, using a risk-based approach via the Privacy Rule (16 C.F.R. Part 313) and Safeguards Rule (16 C.F.R. Part 314).
Key Components
- **Privacy RuleRequires initial/annual notices and opt-out rights for nonaffiliated third-party sharing.
- **Safeguards RuleDemands a written security program with nine elements, including risk assessments, Qualified Individual oversight, encryption, testing, and vendor management.
- **Pretexting ProvisionsProhibits obtaining NPI under false pretenses. Enforced by FTC for non-banks; compliance through programs, audits, no formal certification.
Why Organizations Use It
GLBA ensures legal compliance amid FTC enforcement (penalties up to $100,000/violation), mitigates breach risks, and builds customer trust. It drives risk management, vendor oversight, and reputational advantages in finance.
Implementation Overview
Phased rollout: scoping NPI, risk assessment, policy development, technical controls (MFA, encryption), training, testing. Applies broadly to banks, fintechs, tax firms; U.S.-focused, scalable by size.
Key Differences
| Aspect | PDPA | GLBA |
|---|---|---|
| Scope | Personal data collection, use, disclosure in private sector | Nonpublic personal information privacy and security |
| Industry | All private sector organizations in Singapore/Thailand/etc. | Financial institutions including non-banks (US federal) |
| Nature | Mandatory national privacy regulation with PDPC enforcement | Mandatory US federal law with FTC/banking regulator enforcement |
| Testing | DPIAs, PATO self-assessments, internal audits | Annual penetration tests, vulnerability assessments, risk assessments |
| Penalties | SGD 1M fines or 10% revenue (Singapore) | $100K per violation civil penalties, criminal imprisonment |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PDPA and GLBA
PDPA FAQ
GLBA FAQ
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