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The Personal Data Protection Act (PDPA) in Thailand has put a significant burden on companies to ensure the security and privacy of their customer data. However, many businesses must implement more checklist compliance, putting themselves at risk of substantial fines. In this article, we’ll explore the pitfalls of superficial PDPA compliance vs  Data Lifecycle Management compliance approach and how embracing a data lifecycle management strategy can ensure compliance and deliver significant business benefits and a competitive edge. A checklist approach always concentrates on local laws rather than international privacy laws. A data Lifecycle approach provides an elastic compliance strategy that grows organically with your operations.


Data Discovery and Data Mapping

Superficial Compliance: Checking the Boxes

  • Companies often limit their efforts to superficial data mapping, merely identifying where personal data resides without understanding how it flows through their organisation.

Comprehensive Approach: Understanding the Data Flow

  • A data lifecycle management strategy begins with comprehensive data discovery and mapping, providing a deeper understanding of data sources and how data is processed.


Record of Processing Activities

Superficial Compliance: Minimal Documentation

  • PDPA compliance checklists often lead to minimal documentation of processing activities, missing essential details that regulators might demand.

Comprehensive Approach: Detailed Record-Keeping

  • Implementing a data lifecycle approach involves maintaining detailed records of processing activities, which can demonstrate compliance and transparency to authorities.


Data Subject Access Request Policies

Superficial Compliance: Basic Request Handling

  • Many businesses have rudimentary data subject access request policies that may not meet PDPA requirements.

Comprehensive Approach: Efficient Request Handling

  • A robust data lifecycle strategy ensures the development of efficient data subject access request policies, enabling timely and accurate responses to requests.


Data Breach Response Teams and Policies

Superficial Compliance: Lackluster Preparation

  • Superficial compliance often results in underprepared data breach response teams and inadequate policies for handling data breaches.

Comprehensive Approach: Effective Response Plans

  • Companies following a data lifecycle management approach invest in well-prepared data breach response teams and policies to minimise the impact of data breaches and protect their customers.


Data Access and Data Protection Policies and Processes

Superficial Compliance: Cookie-Cutter Solutions

  • Superficial compliance can lead to generic data access and protection policies and processes that do not adequately safeguard sensitive data.

Comprehensive Approach: Tailored Solutions

  • A comprehensive approach tailors data access and data protection policies and processes to the specific needs and vulnerabilities of the organisation, ensuring a higher level of protection.


Third-Party Vendor Due Diligence and Contracts

Superficial Compliance: Overlooking Vendor Risks

  • Many companies neglect the due diligence required for third-party vendors and may not establish adequate contracts to protect data shared with external parties.

Comprehensive Approach: Rigorous Vendor Oversight

  • A data lifecycle management strategy incorporates stringent due diligence processes for third-party vendors and enforces secure contracts to safeguard data shared with external entities.


Board of Directors, Funding, and Resources

Superficial Compliance: Token Support

  • Superficial compliance often results in a lack of commitment and investment from the board of directors, leading to inadequate funding and resources for data protection initiatives.

Comprehensive Approach: Top-Down Commitment

  • Companies adopting a data lifecycle approach prioritise commitment from the board, ensuring sufficient funding and resources for comprehensive PDPA compliance efforts.


Comprehensive PDPA Training and Awareness Campaigns

Superficial Compliance: Inadequate Staff Training

  • Superficial compliance often underestimates the importance of PDPA training and awareness campaigns, leaving employees ill-prepared.

Comprehensive Approach: Informed Workforce

  • A data lifecycle strategy incorporates comprehensive training and awareness campaigns to continually educate employees about the importance of data protection, turning them into data champions.


Unlocking Employee Engagement

Embracing a comprehensive approach to PDPA compliance reduces the risk of fines and fosters a culture of data protection within the organisation. Employees become engaged and actively safeguard data by forming a team of data champions across the business, creating a more robust and compliant organisation.


Fines for Noncompliance

The PDPA in Thailand imposes significant noncompliance fines, including penalties for unauthorised data processing, failure to respond to data subject access requests, and inadequate data breach reporting. Fines can range from 1 million to 5 million Thai Baht, depending on the violation. Additionally, companies failing to comply may face imprisonment of up to six months for responsible individuals.

In conclusion, choosing between superficial PDPA compliance and a comprehensive data lifecycle management strategy can make or break a business. By addressing the critical areas mentioned above and forming a workforce of data champions, companies mitigate the risk of substantial fines and establish a competitive advantage through data security, transparency, and customer trust. It’s time for Thai businesses to move beyond mere checklists and embrace a holistic data protection and privacy approach.

What is your organisation’s  PDPA Compliance position today? Formiti has delivered data lifecycle projects across the world for clients. It’s time to discard the checklist compliance approach.