New Report on Limits of “Consent” in Singapore’s Data Protection Law


Today, the Future of Privacy Forum (FPF) and Asian Business Law Institute (ABLI), as part of their ongoing joint research project: “From Consent-Centric Data Protection Frameworks to Responsible Data Practices and Privacy Accountability in Asia Pacific,” are publishing the thirteenth in a series of detailed jurisdiction reports on the status of “consent” and alternatives to consent as lawful bases for processing personal data in Asia Pacific (APAC).

This report provides a detailed overview of relevant laws and regulations in Singapore, including:

notice and consent requirements for processing personal data;the status of alternative legal bases for processing personal data which permit processing of personal data without consent if the data controller undertakes a risk impact assessment (e.g., legitimate interests); andstatutory bases for processing personal data without consent and exceptions or derogations from consent requirements in laws and regulations.

The findings of this report and others in the series will inform a forthcoming comparative review paper which will make detailed recommendations for legal convergence in APAC.

Singapore’s Data Protection Landscape

Singapore’s Personal Data Protection Act 2012 (PDPA), which was passed in November 2012 and significantly reviewed in 2020, with the stated purpose of governing the collection, use, and disclosure of personal data by organizations in a manner that recognizes not only individuals’ right to protection of their personal data but also organizations’ needs to collect, use, and disclose personal data.

The PDPA sets the baseline standard of protection for personal data in Singapore, though organizations which are subject to sector-specific

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