30 July 2019

On 28 June 2019, the Info-communications Media Development Authority (“IMDA”) and Personal Data Protection Commission (“PDPC”) announced the first comprehensive Trusted Data Sharing Framework (“Framework”) to facilitate trusted data sharing between organisations. For the purposes of the Framework, “data” refers to both personal and business data.

The Framework is designed to:

  • provide an overview of the key areas in data sharing; 
  • highlight key considerations in each area; 
  • facilitate data sharing conversations with data sharing partners and stakeholders; and 
  • help users think through the entire process to structure their data sharing arrangements.

The Framework helps organisations establish a set of baseline practices by providing a common “data-sharing language”, and suggesting a systematic approach to the broad considerations for establishing trusted data sharing partnerships. It incorporates content from existing PDPC guides on personal data anonymisation and sharing, new materials such as a guide to data valuation for data sharing, and sample legal templates to enable contractual data sharing. When using the Framework, organisations will also be guided through the regulatory considerations, and the contractual, technical and operational safeguards needed in a data sharing arrangement.

Key considerations in data sharing

The Framework is organised into four parts which are not sequential. Organisations may choose to use them in any sequence, depending on their needs, but should not omit any part. The four parts of the Framework are set out below:

  • Data sharing strategy: This part provides information on what data will be useful to be shared, how this data can be valued, and the various arrangements or models that can be used for the sharing of the data. 
  • Legal and regulatory considerations: Organisations will be guided on the compliance requirements for data sharing, and how to structure the legal relationship to enable trusted data sharing between parties. 
  • Technical and organisation considerations: This part offers guidance on technical considerations and possible mechanisms required for moving data to other organisations. 
  • Operationalising data sharing: This part highlights the additional considerations after data sharing has taken place.

Key roles in data sharing

The Framework provides an overview of the data sharing ecosystem and the key roles in the data sharing ecosystem. Four key roles are identified in the Framework as follows:

  • Authority: An authority is usually not directly involved in data sharing, but can influence the data sharing activities through legislative reviews, issuance of the guidelines, standards or accreditation schemes. It could be an institution or organisation empowered to operate a supervisory function related to the ecosystem, or may refer to the regulator (or other governing bodies), or industry bodies with oversight mandates or other practical influence (e.g. industry associations and standards institutes). 
  • Data provider: This refers to creators, licensees or sellers of data. 
  • Data consumer: This refers to recipients collecting or buying external data for their purposes, such as to generate additional insights and supplement internal functions. 
  • Data service providers: This refers to organisations providing data services supporting the data sharing ecosystem. Services can include, but are not limited, to (1) providing technical means (e.g. a platform) to facilitate data exchange, (2) data preparation, data management and technical/risk/governance advisory, and (3) acquiring data from providers (may include processing to enhance its value) and supplying data to data consumers or marketplaces.

Trust principles

The Framework introduces six trust principles as foundations to forming a trusted data sharing partnership: transparency, accessibility, standardisation, fairness and ethics, accountability and security and data integrity.

Reference materials

The following materials are available on the IMDA website www.imda.gov.sg:


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