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PDPC Advisory Guidelines on Use of Personal Data in Generative AI

Advisory Guidelines on Use of Personal Data in Generative AI

Personal Data Protection Commission, Singapore

The guidelines clarify how the PDPA applies across the generative AI lifecycle. Development: web-scraped data that is genuinely publicly available may rely on the Publicly Available Exception in paragraph 1 of Part 2 of the First Schedule instead of consent, but data behind digital barriers (paywalls, registration, authentication, geo/age gates, anti-scraping controls) requires a documented case-by-case assessment; where an organisation trains on its own User Data, a general “product improvement” statement is not sufficient consent and an AI-Specific Notification is required. Deployment: stakeholders are classified as Model Providers, System Providers and System Deployers, each mapped to organisation or data intermediary status. Post-deployment: access and correction obligations apply to personal data used for model or system development. The guidelines are advisory and the PDPA prevails in the event of inconsistency.

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

Does this apply to me?

A Chinese AI company is directly addressed by these guidelines when it: (1) scrapes web data containing personal information about individuals in Singapore for pre-training or fine-tuning; (2) uses conversations, uploads or behavioural logs generated by Singapore users of its product to train or fine-tune models; (3) supplies model APIs or SaaS to Singapore enterprise customers and therefore processes their end-users’ prompts and outputs at inference; or (4) deploys agentic systems in Singapore that can reach across systems into enterprise personal data.

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

Application timeline

  1. 2024-03-01

    PDPC issues the foundational AI Recommendation and Decision Systems guidelines

    Establishes the baseline reading of the business improvement exception, the research exception and AI notification transparency, on which the generative AI guidelines build.

  2. 2026-07-20

    Advisory Guidelines on Use of Personal Data in Generative AI issued

    From issuance, PDPC applies these guidelines when interpreting the PDPA across generative AI model development, system deployment and handling of individual requests.

Obligations (5)

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

Assess and document reliance on the Publicly Available Exception for training data

Severity Criticalparas 3.1–3.9

For every scraped corpus used in pre-training or fine-tuning, assess whether the personal data in it is publicly available. A digital barrier does not by itself defeat public availability, but the assessment must weigh the barrier’s purpose and effect, the number and complexity of steps needed to reach the data, and whether the data is obtainable without restriction elsewhere. Where it is reasonably arguable that the data behind a barrier is not publicly available and the organisation nonetheless relies on the exception, it must record the assessment and reasoning in a DPIA or other written record and produce it if PDPC asks.

Applies when
Model Providers and dataset suppliers that build training corpora by web scraping.
Evidence to retain
  • · Inventory of scraped sources annotated with barrier type
  • · Per-source public-availability assessment records
  • · Data protection impact assessment (DPIA)
  • · Record of robots.txt and terms-of-service compliance checks for the crawl

Estimated first-time effort: 10–25 person-days (estimate, not a commitment)

Provide an AI-Specific Notification before training on User Data

Severity Criticalparas 4.1–4.8 (duty at 4.4; encouraged contents at 4.6)

Where User Data is used for large-scale training or fine-tuning of generative AI models, a general “new product development” statement is not sufficient consent: para 4.4 states that organisations must provide AI-Specific Notifications for this purpose. The form and wording are for the organisation, but individuals must be able to understand the types of personal data affected, how they will be used to train or fine-tune the model, and the functions of those models. Para 4.6 goes on to say organisations are encouraged to provide, to the extent practicable, four items — the model functions requiring personal data, a clear description of the types of personal data used, how the data will be used to train or fine-tune the model, and how individuals can decline or withdraw consent. Those four are best practice rather than a mandatory checklist, but should be treated as PDPC’s review baseline. Layered notification is acceptable, as is a single notification covering several models; consent to processing beyond what is reasonable to provide the product must not be a condition of supply.

Applies when
Chinese AI companies that offer apps, platforms or consumer services directly to individuals in Singapore and wish to reuse their conversations, uploads or behavioural data for model training.
Evidence to retain
  • · AI-Specific Notification text with version history
  • · Privacy policy update announcement and in-product notice screenshots
  • · Opt-out and withdrawal mechanism plus execution records
  • · Reconciliation records between training datasets and users who withdrew consent

Estimated first-time effort: 8–20 person-days (estimate, not a commitment)

Map the organisation’s role in the generative AI stack and implement the matching obligations

Severity Highparas 6.1–6.3, 7.1–7.5, 8.1–8.3, 9.1

Determine, per business line, whether the company is a Model Provider, System Provider or System Deployer, and whether in that capacity it is an organisation or a data intermediary, then configure the obligation set accordingly. A Model Provider that processes personal data for its own purposes — including harvesting downstream prompts and inputs for model development — is an organisation subject to all PDPA obligations; when running inference or hosting data for downstream customers it is a data intermediary owing at least the protection and retention-limitation obligations. The same entity may switch roles between scenarios, and each must be documented in policy.

Applies when
Chinese AI companies that simultaneously run foundation models, model APIs, vertical SaaS and internal deployments. Open-weight Model Providers with no access to downstream personal data are not subject to PDPA obligations in respect of that data.
Evidence to retain
  • · Business-line to role to obligation mapping table
  • · Contract clauses distinguishing organisation and data intermediary capacity
  • · Internal policies and procedures per role
  • · Statement of downstream data-access boundaries for open-weight releases

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

Assign ownership and safeguards for prompts, outputs and agent activity data

Severity Highparas 7.5, 8.2–8.3, 9.1–9.5

System Deployers must identify and register the new data sources their systems create — end-user prompts and inputs, generated outputs, agent or tool activity data, and connected internal enterprise data — assign responsibility for each, implement matching safeguards, and educate internal and external users on what categories of personal data may be entered and how it will be processed. Where systems have agentic functionality, deployers must regularly review the sufficiency of safeguards and be transparent about the privacy-utility trade-off. Model and System Providers should disclose downstream the safeguards implemented, testing and performance metrics such as the likelihood of data leakage, and incident response and breach-notification procedures.

Applies when
Deployers launching AI assistants, support bots, document workflows or agentic systems in Singapore, and the Model and System Providers supplying them.
Evidence to retain
  • · Register of new data sources with assigned ownership
  • · Guidance on data types permitted in prompts plus staff training records
  • · Access controls and redaction configuration for prompt logs
  • · Downstream-facing safeguards information sheet including data-leakage test metrics
  • · Privacy-utility trade-off assessment for agentic use cases

Estimated first-time effort: 10–25 person-days (estimate, not a commitment)

Handle access and correction requests concerning personal data in models and systems

Severity Mediumparas 10.1–10.5

Access and correction obligations apply to personal data collected, used or disclosed for model or system development and deployment. Organisations must accede unless a PDPA exception applies — for example where the burden or expense of access would be unreasonable to the organisation or disproportionate to the individual’s interests, or where there are reasonable grounds that a correction should not be made. Data transferred to a data intermediary remains under the organisation’s control and must be covered in the response. The guidelines acknowledge the technical difficulty created by embeddings and context windows, but this is not an automatic exemption.

Applies when
Any entity acting as an organisation in Singapore that uses personal data to build or operate generative AI models and systems.
Evidence to retain
  • · Searchable index or data-lineage records for training corpora and User Data
  • · Register of access and correction requests
  • · Written justification and technical-limitation explanation where an exception is relied on
  • · Records of retrieval and correction instructions issued to data intermediaries

Estimated first-time effort: 8–20 person-days (estimate, not a commitment)

Penalties

The guidelines carry no penalties of their own; breaches of the underlying PDPA obligations attract directions and financial penalties under ss.48I and 48J (caps as set out under sg-pdpa). The guidelines expressly require an organisation relying on the Publicly Available Exception for data behind a digital barrier to produce a data protection impact assessment or other written record if PDPC asks it to justify that reliance.

Known uncertainty

The guidelines are advisory, not legally binding, and expressly do not modify the legal effect of the PDPA; PDPC may issue further detail on agentic scenarios and content provenance. The guidelines cross-reference IMDA’s Transparency Guidelines for Generative AI Chatbots and Model AI Governance Framework for Agentic AI, neither of which was independently verified in this research pass.

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.

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WCAG 2.1 AA accessibility target
PDPC Advisory Guidelines on Use of Personal Data in Generative AI · Obligations & official sources | HaiWen HQ