24 August 2017

Allen & Gledhill Partner Alexander Yap and Associate Claudice Wee contributed this article to the Personal Data Protection Commission’s (PDPC) inaugural issue of the Personal Data Protection Digest. The article considers whether the practical application of the Personal Data Protection Act raises the question of the appropriate apportionment of liability between organisations and their data intermediaries for compliance with the Act. The article highlights that it is often not clear when a service or software provider is to be considered a “data intermediary”, and looks at the types of activities that may cause organisations to become data intermediaries, using as a backdrop the typical developmental “life cycle” of systems. To access the entire issue of the Personal Data Protection Digest from the PDPC’s website, please click here.

To read the article, please click here.