Skip to content
Back to policy library
SingaporeIn forceRelevance to Chinese AI firms: HighData & privacyAI regulation

PDPC Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems

Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems

Personal Data Protection Commission, Singapore

The guidelines explain how organisations may lawfully use personal data to build and deploy recommendation and decision systems embedding machine learning models. They cover four areas: the two consent exceptions available for development, testing and monitoring — the Business Improvement Exception and the Research Exception, each with conditions; the notification duty at deployment, requiring disclosure of the product function, the types of personal data processed, how that processing relates to the feature, and the features most likely to influence the output; the accountability duty to document AI practices and safeguards in written policies and to publish them proactively; and procurement, listing service-provider best practices such as data mapping and labelling and provenance records tracing training-data lineage.

Verified against official sources · 2026-09-12Verified against official text

Does this apply to me?

Applies to a Chinese AI company that: (1) trains recommendation, risk, matching or scoring models on customer data lawfully collected by its Singapore subsidiary or local entity; (2) conducts joint AI R&D with a Singapore organisation involving mutual disclosure of personal data; (3) delivers bespoke or configurable AI systems to Singapore enterprise customers and thereby processes their data as a data intermediary; or (4) launches personalised recommendation or automated scoring features in Singapore that must be explained to individuals.

Key industries: Enterprise SaaS, Fintech AI, GenAI & foundation models, Healthcare AI, Computer vision

Application timeline

  1. 2024-03-01

    Guidelines issued, setting out how the Business Improvement and Research Exceptions apply to AI system development

    From issuance, organisations can rely on these guidelines to determine whether lawfully collected personal data may be used without consent to develop, test and monitor AI systems.

  2. 2026-07-20

    The generative AI guidelines are issued and apply alongside these guidelines

    Generative scenarios must be read against both documents; these guidelines remain the baseline for consent exceptions and AI notification transparency.

Obligations (5)

Each states its trigger, the evidence to retain and the clause it comes from

Verify the conditions before relying on the Business Improvement Exception

Severity Highparas 5.1–5.2; First Schedule Part 5 para 1(2)

The Business Improvement Exception lets an organisation use, without consent, personal data it previously collected in accordance with the PDPA, for improving or enhancing existing goods and services or developing new ones; improving or developing methods or processes for business operations relating to those goods and services; learning or understanding individuals’ behaviour and preferences, including for segmented groups; and identifying, personalising or customising goods and services for individuals. Before relying on it, confirm and record that the purpose cannot reasonably be achieved without the data in individually identifiable form.

Applies when
Organisations training or tuning AI recommendation, scoring or risk models on user data lawfully collected by their Singapore entity.
Evidence to retain
  • · Written applicability assessment relying on the Business Improvement Exception
  • · Traceability record of the lawfulness of the source collection
  • · Technical justification that the purpose cannot be met with non-identifiable data
  • · Statement linking the training purpose to the organisation’s goods and services

Estimated first-time effort: 4–10 person-days (estimate, not a commitment)

Meet the four conditions of the Research Exception and assess impracticability of consent

Severity Highparas 6.1–6.4

For R&D without immediate product application, the Research Exception is available only if all of the following hold: the research purpose cannot reasonably be accomplished unless the data is in individually identifiable form; there is a clear public benefit; the results will not be used to make any decision affecting the individual; and any published results do not identify the individual. Disclosure to another party under the exception — including joint development of new AI systems — additionally requires an assessment that obtaining consent would be impracticable.

Applies when
Chinese AI companies conducting joint model research with Singapore universities, hospitals or corporates involving exchange of personal data.
Evidence to retain
  • · Point-by-point assessment of the four Research Exception conditions
  • · Public-benefit justification and research protocol
  • · Internal undertaking and technical segregation ensuring results are not used in decisions affecting individuals
  • · Data-use restriction clauses in the joint research agreement

Estimated first-time effort: 4–10 person-days (estimate, not a commitment)

Give individuals an intelligible notification of how the AI feature uses their personal data

Severity Highparas 9.5–9.6

When deploying a product with AI recommendation or decision features, explain so far as practicable: the product function requiring collection and processing of personal data; a general description of the types of personal data collected and processed; how that processing is relevant to the product feature; and the specific data features most likely to influence the feature’s output. Delivery may be through pop-up notifications or publicly accessible written policies, as the organisation judges appropriate.

Applies when
Chinese AI products offered to individuals in Singapore with personalisation, ranking, matching or automated scoring features.
Evidence to retain
  • · AI feature explanation text including the features influencing outputs
  • · Screenshots and delivery logs of the notification surface
  • · Consistency check between feature-importance analysis and public statements
  • · Accessibility verification of the published policy page

Estimated first-time effort: 5–12 person-days (estimate, not a commitment)

Document AI governance practices and safeguards in written policies and publish them proactively

Severity Mediumparas 10.2–10.4; PDPA s. 12

Section 12 of the PDPA requires organisations to develop policies and practices to meet their obligations. Organisations using AI systems should set out in written policies the practices and safeguards adopted to achieve fairness and reasonableness, at a level of detail proportionate to the risk of the use case — potential harm to the individual and the AI system’s degree of autonomy. Section 12(d) requires disclosure on request, but the guidelines recommend proactive publication on the organisation’s website, including a short-form version.

Applies when
Organisations operating AI systems in Singapore, particularly higher-autonomy use cases or those capable of materially affecting individuals.
Evidence to retain
  • · Written AI governance policy covering fairness and reasonableness safeguards
  • · Record of per-use-case risk tiering and the resulting level of disclosure
  • · Public-facing page and short-form policy
  • · Minutes of the annual policy review

Estimated first-time effort: 4–10 person-days (estimate, not a commitment)

As an AI service provider, maintain training-data mapping, labelling and provenance records

Severity Mediumparas 11.2–11.3

Service providers that build bespoke or fully customisable AI systems and thereby process personal data as data intermediaries should, at the pre-processing stage, use data mapping and labelling to track what enters the training dataset, and maintain provenance records identifying the source of training data and how it was transformed during data preparation. These records support assessment of unauthorised access or modification of the training set, and let the deploying organisation judge whether a notifiable data breach has occurred and the scope of impact of any change to the training set.

Applies when
Chinese AI vendors that customise models, perform data annotation or provide managed training services for Singapore customers.
Evidence to retain
  • · Training-data mapping and labelling inventory
  • · Provenance records tracing source to transformation to inclusion
  • · Training-set integrity checks and change audit logs
  • · Records identifying sensitive personal data and the calibrated handling applied

Estimated first-time effort: 6–15 person-days (estimate, not a commitment)

Penalties

No standalone penalties; breaches of the underlying PDPA consent, notification and accountability obligations are dealt with under ss.48I and 48J of the PDPA.

Related standards

  • ISO/IEC 42001 Artificial Intelligence Management System (AIMS) · ISO/IEC 42001:2023 (edition 1, dated 2023-12); European adoption EN ISO/IEC 42001:2026
  • ISO/IEC 27701:2025 Privacy information management systems — Requirements and guidance · ISO/IEC 27701:2025 (edition 2, 2025-10), cancelling and replacing ISO/IEC 27701:2019

Sources (3)

Content as of 2026-09-12 · corpus 2026.09|Compiled from public official sources with links and review dates for compliance decision support. Rules change; have licensed professionals review before external disclosure, regulatory filing or contractual commitments.

Related regulations

GDPR · PIPL · CCPA control mapping
Traceable AI · cited when sourced
ISO 27001 alignment in progress
WCAG 2.1 AA accessibility target
PDPC Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems · Obligations & official sources | HaiWen HQ