Overview On The Appointment Of Personal Data Protection Officer Under The Personal Data Protection Act 2010

Introduction

Section 12A of the Personal Data Protection Act 2010¹ [Act 709] ("PDPA"), which will come into effect on 1 June 2025 requires data controller and data processor to appoint one or more data protection officers ("DPO") who shall be accountable to the data controller and the data processor for the compliance with the PDPA.

Pursuant to the above and Section 48(g) of the PDPA, the Personal Data Protection Commissioner ("Commissioner") has recently issued:

(a) Circular of Personal Data Protection Commissioner No. 1/2025 (Appointment of Data Protection Officer) ("Circular No. 1/2025"); and

(b) Personal Data Protection Guideline: Appointment of Data Protection Officer Version 1.0 ("DPO Guideline").