SINGAPORE Law and Practice Contributed by: Chong Kin Lim, David N. Alfred and Anastasia Chen, Drew & Napier LLC
tion of specified PDPA provisions may bring a private civil action against the organisation in court, without first obtaining a finding from the PDPC. Recent deci - sions, including the High Court’s ruling in Piper, Martin v Singapore Kindness Movement [2025] SGHC 173 ( Piper, Martin ) and Reed, Michael v Bellingham, Alex (Attorney-General, intervener) [2022] SGCA 60 ( Reed ), illustrate the approach taken by the courts. Claimants must establish a statutory breach, causation, and actionable loss and damage. Crucially, the Court in Piper, Martin emphasised that a “strict causal link” must be established in order for a claim for loss or damage to succeed. Under Section 48O(3), the court may grant injunctive or declaratory relief, award dam - ages, or order any other appropriate remedy. While the PDPC itself cannot award compensation, non-material harm is compensable in civil proceed - ings. However, the Singapore courts take a cautious approach towards awarding non-material damages. The Court of Appeal in Reed emphasised that courts assess such harm on a fact-specific basis, consider - ing (among other things): • the sensitivity of the personal data involved; • the nature and duration of the breach; • the defendant’s conduct (eg, negligent versus mali - cious); • the risk of future misuse; and • the actual impact on the claimant. 2.2 Recent Case Law Recent case law has clarified key contours of data protection litigation in Singapore, where court actions remain relatively limited. In Piper, Martin v Singapore Kindness Movement [2025] SGHC 173, the High Court clarified the parameters of “deemed consent” and the investigation exception under the PDPA, holding that disclosures of personal data must be objectively nec - essary and reasonable for the stated purpose, even in the context of internal investigations. See 2.1 Privacy Litigation Overview for the Court’s holding on require - ments for loss or damages claims to succeed. Read together with Reed , these decisions establish that while non-material harm such as emotional dis - tress can be compensable, mere loss of control over
personal data is insufficient, and liability will turn on necessity, proportionality and proof of actual impact. 2.3 Collective Redress Mechanisms Singapore does not provide collective redress mecha - nisms to safeguard the shared interests of multiple individuals. 3. Requirements for the Protection and Processing of Non-Personal Data 3.1 Objectives and Scope of Data Regulation Singapore currently has no dedicated legislation spe - cifically regulating non-personal data or cross-sector data access comparable to the EU Data Act. The gov - ernance of technologies such as IoT, cloud comput - ing and other data processing services falls primarily under the broader PDPA and the Cybersecurity Act 2018, alongside sector-specific guidance from agen - cies such as the IMDA. The Data Protection Provisions continue to apply to IoT devices and other connected services that collect personal data, ensuring that organisations deploying such technologies maintain responsible data manage - ment practices. Further, the Amendment Act will introduce a new data portability obligation, which requires an organisation, upon an individual’s request, to transfer the individual’s personal data in its possession or control (including data generated through IoT and connected devices) to another organisation in a commonly used, machine- readable format. However, it is not yet in force. Data intermediaries processing data on behalf of oth - ers are also subject to specific obligations under the PDPA, namely the protection obligation, the retention limitation obligation, and the data breach notification obligation (where a data intermediary becomes aware, or has reasonable grounds to suspect, that a data breach has occurred involving personal data it pro - cesses for another organisation, it is required to inform that organisation promptly).
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