Singapore: Closed consultation on Advisory Guidelines on the Use of Personal Data in AI Systems under the Personal Data Protection Act (PDPA)

On 31 August 2023, the public consultation closed on the Personal Data Protection Commission's (PDPC) draft version of the Advisory Guidelines on the Use of Personal Data in AI Systems under the Personal Data Protection Act (PDPA). The guidelines aim to clarify how the PDPA applies to the collection and use of personal data by organisations to develop and deploy AI Systems with machine learning models. The Guidelines cover scenarios where organisations can use the Business Improvement and Research Exception, allowing them to use personal data without prior consent. However, when deploying AI Systems that collect and use personal data in products or services, organisations must adhere to consent and notification obligations. Users should be informed about the purpose and intended use of their personal data when consent is sought. Additionally, the guidelines highlight that service providers developing and deploying bespoke AI Systems may be considered data intermediaries and must comply with relevant obligations under the PDPA.