PDPA Compliance & Exceptions: What Singapore SMEs Must Address
Singapore's Personal Data Protection Act (PDPA) applies to businesses of all sizes, including SMEs. Yet, many SMEs underestimate the effort required to comply. Exceptions temporary deviations from compliance or security controls are common, but without proper oversight, they can create significant risks.
Why Exceptions Happen in SMEs
Common Compliance Challenges
- Legacy IT systems that don't meet encryption or access control standards.
- Third-party vendors processing customer data without full contractual safeguards.
- Operational pressures leading to delays in patching or backup implementation.
These scenarios represent "exceptions" to PDPA obligations. If unmanaged, they expose SMEs to enforcement actions by the Personal Data Protection Commission (PDPC).
What SMEs Must Address
1. Access Control Exceptions
Staff with broader access to personal data than necessary.
2. Retention Exceptions
Data kept beyond required periods for convenience.
3. Vendor Exceptions
Cloud or SaaS partners not fully compliant with PDPA.
4. Incident Handling Exceptions
Gaps in reporting timelines or breach notifications.
Best Practices
Implementation Guidelines
- Centralize exception logging: Keep a register linking each exception to PDPA requirements.
- Assign a Data Protection Officer (DPO): Required under PDPA, the DPO should review and approve exceptions.
- Time-bound reviews: Exceptions should expire or be re-evaluated regularly.
- Document risk acceptance: Management must show they considered risks before allowing exceptions.
Bottom Line
Compliance Success
For Singapore SMEs, PDPA compliance isn't just a legal checkbox. Exception oversight ensures SMEs can demonstrate accountability, transparency, and trustworthiness critical factors in retaining customers and avoiding regulatory penalties.