1. Introduction
As of late, new laws and regulations have been created in order
to address modern concerns. In Malaysia, the Personal Data
Protection Act 2010 ("PDPA") is the core of such system.
The PDPA is then supported by sub-legislations and regulations. For
our discussion herein, we will look into one such regulation, the
newly issued General Code of Practice or, in short,
"GCOP".
Although the GCOP seems to appear as a practical guideline, it
is legally binding. Violations under the same are subject to
penalties under Section 29 of the PDPA. As such, this should not be
taken lightly by the data users that it governs1.
2. The basis behind the GCOP.
Firstly, data users are required to adhere to the PDPA in order
to process and maintain personal data. Some data users are required
to be registered as "registered data user" prior to
processing2 with the Personal Data Protection
Department. Currently, the list of classes of data users that would
require
