SINGAPORE Law and Practice Contributed by: Lim Chong Kin, Drew & Napier LLC
8. Trust Services and Digital Entities 8.1 Trust Services and Electronic Signatures/Digital Identity Schemes Digital Identity Launched in 2003, SingPass is a secure per - sonal authentication system that allows users to access various government services online. Under the National Digital Identity initiative, SingPass, MyInfo (a service that automatical - ly fills out selected personal details for online forms) and MyInfo Business (a service that ena - bles a business to manage the use of its corpo - rate and applicant’s personal data for simpler online transactions) were brought together to provide greater transactional security and ease of use. All SingPass users are automatically pro - vided with a MyInfo profile, which allows them to provide personal data once to digital services and then consent to have their personal data retrieved from government sources to pre-fill forms for digital transactions. As SingPass and MyInfo are managed by the Government Technology Agency (“GovTech”), the data protection provisions in the PDPA do not apply to them and other public agencies. Instead, data management by public agencies is governed by the Public Sector (Governance) Act 2018 and guided by the Government Instruction Manual on Infocomm Technology & Smart Sys - tems Management (previously known as IM8). However, private organisations utilising Sing - Pass and MyInfo to facilitate their transactions are subject to the obligations under the PDPA. As personal data on these platforms is often sensitive data, organisations should take the sensitivity of the personal data into account and implement robust policies and procedures
• pursuant to the prices, terms and conditions of an individualised interconnection agree - ment between the two parties. The IMDA has published the above agreements between dominant licensees and companies on its website, as well as model agreements. Com - panies are encouraged to refer to the terms in the published agreements during their negotia - tions with dominant licensees. Licensees classified by the IMDA as dominant licensees are required to publish RIOs, under which they offer interconnection-related servic - es and mandated wholesale services on prices, terms and conditions that are pre-approved by the IMDA, unless specifically exempted by the IMDA. A telecommunication licensee will be classified by the IMDA as dominant if: • it is licensed to operate facilities used for the provision of telecommunication services that are sufficiently costly or difficult to replicate, such that requiring new entrants to do so would create a significant barrier to rapid and successful entry into the telecommunication market in Singapore by an efficient competi - tor; or • it has the ability to exercise significant market power in any market in Singapore in which it provides telecommunication services. Licensees currently classified as dominant licen - sees include: • Singtel; • StarHub Cable Vision; • NetLink NBN Management Pte Ltd (as trustee-manager of NetLink NBN Trust); and • NetLink Management Pte Ltd (as trustee of NetLink Trust).
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