Exception Management Under Singapore's PDPA: What SMEs Must Do
Singapore's Personal Data Protection Act (PDPA) governs how businesses collect, use, and protect personal data. While SMEs may think compliance is a "big company problem," the reality is that even a small clinic, retailer, or startup could face penalties for mishandling customer data. Exception management formally tracking when your business temporarily deviates from PDPA requirements is often overlooked but essential.
Why Exceptions Arise
SMEs may encounter situations such as:
- Using legacy CRM systems that lack encryption.
- Allowing marketing teams broader access to customer data.
- Delaying patching on systems due to operational disruptions.
Regulatory Risk
These are exceptions to compliance controls, and if unmanaged, they could expose SMEs to enforcement actions by Singapore's Personal Data Protection Commission (PDPC).
The Role of Exception Management
1. Transparency
By documenting exceptions, SMEs can demonstrate accountability during audits or investigations.
2. Risk Mitigation
Exceptions often increase risk; tracking them ensures leaders weigh business impact.
3. Continuous Improvement
Exception logs highlight weak areas in data governance for long-term fixes.
PDPA-Specific Steps
Classify Exceptions by Data Category
Financial, health, or contact information should be flagged.
Time-box Approvals
No exception should be permanent set expiration dates and review cycles.
Assign Data Protection Officers (DPOs)
Required under PDPA, the DPO should oversee exception handling.
The Outcome
Building Trust and Compliance
Instead of scrambling during a breach, SMEs that practice exception management under PDPA can prove due diligence and build trust with customers who expect transparency in how their data is managed.