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In a rapidly globalising digital world, the tentacles of data privacy laws extend far beyond their geographical origins. The European Union General Data Protection Regulation (GDPR),  serves as a prime example, impacting businesses worldwide, including those in Singapore. This article, crafted with Formiti Data International’s expertise, delves into the intricacies of GDPR for Singaporean enterprises, highlighting the pivotal role of Article 27 and offering pragmatic compliance strategies.

Understanding GDPR’s Reach

The GDPR’s jurisdiction transcends European borders, applying to any organisation outside the EU that offers goods or services to individuals in the EU or monitors their behaviour. This extraterritorial scope means a Singaporean business could fall under GDPR’s purview, irrespective of its physical presence in Europe. For example, a Singapore-based e-commerce website that ships goods to EU member states or a mobile app developer collecting data from EU residents would need to comply with GDPR.

Deciphering GDPR Article 27

Article 27 of the GDPR  holds particular significance for non-EU businesses. It mandates the appointment of a European representative for organisations that process data on a large scale or handle special categories of personal data. This representative acts as a point of contact for European data protection authorities and individuals in the EU. Singaporean businesses, therefore, must evaluate their data processing activities to determine if appointing such a representative is necessary.

Singapore’s PDPA vs GDPR

While Singapore’s Personal Data Protection Act (PDPA) shares similarities with the GDPR, compliance with the former does not automatically ensure adherence to the latter. The GDPR encompasses broader and more stringent requirements. For instance, the GDPR’s ‘right to be forgotten‘ and data portability rights are more extensive than those under the PDPA. Recognising these differences is crucial for Singaporean organisations to navigate dual compliance.

Practical Steps for Compliance

  1. Data Mapping: Understand the flow of personal data within your organisation. Identify whether the data pertains to EU citizens and if it falls under GDPR.
  2. Appoint a Representative: If your business falls under the criteria of Article 27, appoint an EU representative to liaise with European data protection authorities.
  3. Review and Update Policies: Ensure your privacy policies and procedures align with GDPR requirements, particularly concerning consent, data subject rights, and data breach notifications.
  4. Data Protection Impact Assessments (DPIAs): Conduct DPIAs for high-risk data processing activities to identify and mitigate risks to data subjects’ rights.
  5. Training and Awareness: Educate your staff about GDPR requirements and the importance of data privacy and security.
  6. Vendor Management: Assess and monitor third-party vendors who handle personal data to ensure they too comply with GDPR.

Real-World Scenarios

To illustrate GDPR’s applicability, consider these scenarios:

  • Likely Under GDPR: A Singaporean online language school offering courses in European languages, priced in Euros, and targeting EU nationals.
  • Likely Under GDPR: A mobile game developer based in Singapore permits EU residents to download their application and register an account. This process involves gathering personal data from users, along with monitoring their application activity and geographical locations. Additionally, when the application operates within the EU, it collaborates with a digital advertising service to deliver targeted advertisements based on the user’s specific location.
  • Unlikely Under GDPR: A Singapore-based café collecting data solely for local employee management, with no service offerings in the EU.


For Singaporean businesses, navigating the complexities of GDPR is not just about legal compliance; it’s about building trust and demonstrating commitment to data privacy. As a leader in global data privacy consultancy, Formiti Data International Ltd. understands the nuances and challenges faced by organisations in achieving compliance. We advocate for a proactive approach, where understanding, planning, and implementing GDPR-compliant practices become integral to your business operations.

GDPR Compliance is included in our comprehensive Singapore PDPA Data Privacy Service