On November 11, 2025, amendments to Taiwan's Personal Data
Protection Act ("PDPA") were promulgated by the
president. Although the amendments have not yet formally taken
effect, the provisions align the PDPA with the EU General Data
Protection Regulation ("GDPR") and therefore merit close
attention.
The provision that should be given primary attention in the
amended Act is Article 12, which—with respect to a personal
data breach, namely where personal data is stolen, altered,
damaged, destroyed, or disclosed—explicitly prescribes the
obligation to inform the data subject and the obligation to notify
the competent authority.
- Regarding the obligation to inform the data subject, when an
enterprise becomes aware that the personal data under its
possession has been subject to a personal data breach, the
enterprise shall, pursuant to Article 12, Paragraph 1, inform the
data subject, and, consistent with Article 34(1) of the GDPR, such
notification is not conditioned