On 4 June 2020, Singapore’s Personal Data Protection Regulations 2014 (Regulations) were amended to specify that recipients of personal data located outside Singapore which are certified under the Asia‑Pacific Economic Cooperation Cross-Border Privacy Rules (APEC CBPR) System, would satisfy the cross-border data transfer requirements under Singapore’s data protection law.
The same outcome would be achieved if the recipient is a data intermediary (i.e., processes personal data on behalf of another), and is certified under the Asia‑Pacific Economic Cooperation Privacy Recognition for Processors (APEC PRP) System.
Prior to these amendments, transferring organisations would have to fulfil other relevant conditions in the Regulations, such as entering into a legally binding data transfer agreement or binding corporate rules with the recipient.
Reed Smith LLP is licensed to operate as a foreign law practice in Singapore under the name and style, Reed Smith Pte Ltd (hereafter collectively, “Reed Smith”). Where advice on Singapore law is required, we will refer the matter to and work with Reed Smith’s Formal Law Alliance partner in Singapore, Resource Law LLC, where necessary.