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Personal Data Protection Act 2012 — Transfer Limitation Obligation

PDPA s. 26

Singapore · July 2, 2014

s. 26(1) bars transferring personal data outside Singapore unless the organisation ensures a standard of protection comparable to the PDPA's will be maintained over it. Regulation 10 makes that concrete: the recipient must be bound by legally enforceable obligations — typically contract, binding corporate rules for intra-group transfers, a certification such as APEC CBPR, or the destination's own law where it provides comparable protection. 'Comparable' is not 'identical': the test is comparable overall effect, not a mirror of the PDPA. Singapore's model is exporter accountability rather than government pre-approval, so there is no filing or adequacy list to consult — the burden is on the organisation to document why its chosen mechanism holds.

Act No. 26 of 2012, s. 26; Personal Data Protection Regulations 2021, reg. 10Read regulation →

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