■ ■ Process for provisioning user
■ ■ Process for de-provisioning user
■ ■ Disciplinary measures for security
Conduct data security/privacy
training for employees.
Conducting data security/privacy training
for employees may prevent potential
security incidents. This preventive
measure allows employees to detect
issues earlier and may prevent more
serious security incidents in the
For good reason, Singapore is
one of the most popular places for
multinational companies to establish
their APAC company headquarters.
With a strong rule of law, Singapore
takes enforcement of its laws seriously and the PDPA is no exception.
The increase in the number of PDPC
enforcement actions shows the coun-
try’s growing intention to ensure the
protection of personal data through
the enforcement of the PDPA. While
the size of the fines levied by the
PDPC for non-compliance has been
relatively modest, it does not take
into account the time and reputa-
tional costs associated with a PDPC
investigation. Entities that operate in
Singapore would be wise to conform
their compliance to the PDPA and to
pay attention to the PDPA’s actions
and public statements. ACC
1 Price WaterhouseCooper, The
Preferred Asian HQ Location,
(January 28, 2015), available at
2 Personal Data Protection Act of
2012, Section 28-30, www.pdpc.
3 Personal Data Protection Commission,
Advisory Guidelines on Enforcement
of the Data Protection Provisions,
(April 21, 2016), www.pdpc.gov.
4 Id. at Section 2.
5 Id. at Sections 15. 3 and 25.
6 Government of Singapore, PDPC Takes
Action Against 11 Organizations for
Breaching Data Protection Obligations,
April 21, 2016, www.pdpc.gov.sg/
9 Section 24 of the PDPA.
10 Decision of the Personal Data
Protection Commission, K Box
Entertainment Group PTE. LTD.,
Finantech Holdings PTE. LTD., 
SGPDPC 1, Section 44 (April 20,
ACC EXTRAS ON… Data privacy regulations
The Environmental Law
Landscape in India: A Walk
Through Consent and Compliance Requirements (Nov. 2016).
Best Practices: Hiring and
Training In-house Counsel in
India (July/Aug. 2015). www.
Learn Your World – India
(April 2015). www.accdocket.
Doing Business in Emerging
Markets: Legal Trends and Tips
Asia Pacific (June 2015).
Using International Treaties and
Agreements to Work Effectively in
International Markets (Oct. 2014).
Doing Business in Global Guide
(July/Aug. 2016). www.acc.com/
Competition Law Multi-Jurisidic-tional Guide (Jan/Feb. 2015).
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