PDPA Data Breach Notification Playbook: The 3-Day Rule
A step-by-step playbook for the PDPA's mandatory data breach notification regime — assessment of notifiability (500+ individuals or significant harm), 3-calendar-day PDPC filing, affected-individual communications, and post-incident evidence.
What Counts as a Notifiable Breach Under the PDPA
This section provides comprehensive guidance on what counts as a notifiable breach under the pdpa as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
The 3-Calendar-Day Clock vs GDPR's 72-Hour Clock
This section provides comprehensive guidance on the 3-calendar-day clock vs gdpr's 72-hour clock as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
Notifiability Assessment: 500-Individual and Significant-Harm Thresholds
This section provides comprehensive guidance on notifiability assessment: 500-individual and significant-harm thresholds as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
Filing the Notification on the PDPC's Online Portal
This section provides comprehensive guidance on filing the notification on the pdpc's online portal as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
Notifying Affected Individuals
This section provides comprehensive guidance on notifying affected individuals as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
Processor Escalation and Group Company Flows
This section provides comprehensive guidance on processor escalation and group company flows as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
Post-Incident Review and PDPC Follow-Up
This section provides comprehensive guidance on post-incident review and pdpc follow-up as it relates to your overall compliance program. Privacy teams that establish strong foundations in this area significantly reduce their regulatory exposure while building operational processes that scale as their data processing activities grow.
Key considerations include understanding the specific regulatory requirements that apply, mapping your current capabilities against those requirements, identifying gaps, and implementing controls that address both immediate compliance needs and long-term risk management objectives. Documentation of your approach is as important as the approach itself — regulators expect to see evidence of a structured, repeatable process.
Practical action
Review your existing policies and procedures against the requirements in this section. Document any gaps and assign remediation owners with clear deadlines.
In this guide
- 1What Counts as a Notifiable Breach Under the PDPA
- 2The 3-Calendar-Day Clock vs GDPR's 72-Hour Clock
- 3Notifiability Assessment: 500-Individual and Significant-Harm Thresholds
- 4Filing the Notification on the PDPC's Online Portal
- 5Notifying Affected Individuals
- 6Processor Escalation and Group Company Flows
- 7Post-Incident Review and PDPC Follow-Up
Put this guide into practice
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