On behalf of the Asia Internet Coalition (AIC) and its members, I am writing to express our sincere gratitude to the Personal Data Protection Commission (PDPC) for the opportunity to submit comments on the Proposed Classes of Personal Data, in regard to the Data Breach Notification Requirement. AIC is an industry association comprising leading Internet and technology companies in the Asia Pacific region with an objective to promote the understanding and resolution of Internet and ICT policy issues.
We commend the PDPC’s efforts on steering this consultation with AIC to strengthen the Personal Data Protection Act (PDPA) to govern the protection and management of personal data by the private sector. The AIC understands the importance of data breach notification requirement, resulting from significant harm to individuals. In view of technological developments, we are also cognisant of the significant challenges, owing to which data protection laws are also shifting towards a risk-based, accountability approach to ensure organizations meet data protection standards.