Standards Comparison

    PDPA

    Mandatory
    2012

    Singapore regulation for personal data protection

    VS

    MLPS 2.0 (Multi-Level Protection Scheme)

    Mandatory
    N/A

    China's mandatory graded cybersecurity protection framework

    Quick Verdict

    PDPA governs personal data privacy across SE Asia jurisdictions, emphasizing consent and rights. MLPS 2.0 mandates graded cybersecurity for China's networks via PSB oversight. Companies adopt PDPA for regional compliance, MLPS for China market access and legal operations.

    Data Privacy

    PDPA

    Personal Data Protection Act 2012

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

    Key Features

    • Mandatory Data Protection Officer appointment
    • 72-hour data breach notification regime
    • Deemed consent and statutory exceptions
    • Transfer Limitation Obligation for cross-border
    • Do Not Call Registry for marketing
    Standard

    MLPS 2.0 (Multi-Level Protection Scheme)

    Multi-Level Protection Scheme 2.0

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

    Key Features

    • Five-level impact-based system classification
    • Mandatory PSB registration for Level 2+ systems
    • Scalable technical controls for cloud, IoT, ICS
    • Third-party audits with 75/100 passing score
    • Ongoing governance and incident reporting obligations

    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 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 through obligations like consent, notification, and security.

    Key Components

    • Nine core **Data Protection Obligationsconsent, notification, access/correction, accuracy, protection, retention limitation, transfer limitation, accountability, breach notification.
    • Built on PDPC advisory guidelines and amendments (2020-2021).
    • Mandatory DPO appointment and Do Not Call Registry.
    • Compliance via Data Protection Management Programme (DPMP), no formal certification but PDPC enforcement.

    Why Organizations Use It

    • Legal compliance to avoid fines up to SGD 1 million.
    • Risk mitigation for breaches and enforcement.
    • Builds stakeholder trust, enables data-driven innovation.
    • Strategic advantages in market access and partnerships.

    Implementation Overview

    • **Phased risk-based approachgovernance, data mapping, policies, controls, training, monitoring.
    • Applies to all organizations handling Singapore personal data.
    • Key activities: inventories, DPIAs, vendor contracts, breach playbooks.
    • Ongoing audits and PDPC guidance adherence (no certification required).

    MLPS 2.0 (Multi-Level Protection Scheme) Details

    What It Is

    MLPS 2.0 (Multi-Level Protection Scheme) is China's legally mandated cybersecurity regulation under the 2017 Cybersecurity Law (Article 21). It is a graded protection framework requiring network operators to classify systems into five levels based on compromise impact to national security, social order, and public interests. Its impact-based approach scales technical, organizational, and governance controls accordingly.

    Key Components

    • Core domains: physical security, network protection, data security, access control, monitoring, governance.
    • Standards like GB/T 22239-2019, GB/T 25070-2019 define baselines and extensions for cloud, IoT, ICS, big data.
    • Built on common controls plus level-specific requirements.
    • Compliance via self-classification, third-party audits (75/100 score min for Level 2+), PSB approval.

    Why Organizations Use It

    • Mandatory for China operations to avoid fines, suspensions.
    • Enhances resilience, aligns with data laws (DSL, PIPL).
    • Builds regulator trust, enables market access.

    Implementation Overview

    Phased: scoping, classification, gap analysis, remediation, audits, ongoing re-evaluations. Applies to all sizes in China; Level 3+ needs annual audits. (178 words)

    Key Differences

    Scope

    PDPA
    Personal data protection, consent, rights, transfers
    MLPS 2.0 (Multi-Level Protection Scheme)
    Graded cybersecurity for networks, systems, infrastructure

    Industry

    PDPA
    All sectors in Singapore/Thailand/Taiwan/Malaysia
    MLPS 2.0 (Multi-Level Protection Scheme)
    All network operators in mainland China

    Nature

    PDPA
    Principles-based privacy regulation, mandatory
    MLPS 2.0 (Multi-Level Protection Scheme)
    Mandatory graded cybersecurity scheme, law enforcement

    Testing

    PDPA
    Self-assessments, no mandatory external audits
    MLPS 2.0 (Multi-Level Protection Scheme)
    Third-party audits, PSB approval for Level 2+

    Penalties

    PDPA
    Fines up to SGD 1M/RM 1M, enforcement notices
    MLPS 2.0 (Multi-Level Protection Scheme)
    Fines, operations suspension, PSB inspections

    Frequently Asked Questions

    Common questions about PDPA and MLPS 2.0 (Multi-Level Protection Scheme)

    PDPA FAQ

    MLPS 2.0 (Multi-Level Protection Scheme) FAQ

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