CIPP/A key terms
CIPP/A · Get comfortable with the vocabulary.
- Omnibus data protection law
- Related: Sectoral privacy regulation, Singapore Personal Data Protection Act (PDPA), Act on the Protection of Personal Information (APPI)
A single statute governing how personal data is processed across the private sector generally, rather than through industry-specific rules; Singapore's PDPA and Japan's APPI are examples.
- Sectoral privacy regulation
- Related: Omnibus data protection law, SPDI Rules 2011
A regulatory approach that imposes privacy duties on particular industries or data types - for example, finance, health or telecommunications - leaving other processing largely unregulated unless a general law also applies.
- Data Protection Authority
- Related: Personal Data Protection Commission (PDPC), Privacy Commissioner for Personal Data (PCPD), Personal Information Protection Commission (PPC)
An independent or semi-independent body established by statute to enforce data protection law, issue guidance, handle complaints and impose sanctions; examples are Singapore's PDPC, Hong Kong's PCPD and Japan's PPC.
- Data localisation
- Related: Cross-border data transfer restriction
A requirement that specified data be stored or processed on equipment physically located within a jurisdiction, sometimes paired with a prohibition on offshore transfer; it appears in Asian sectoral rules rather than as a blanket ban.
- Cross-border data transfer restriction
- Related: Data localisation, APPI cross-border transfer rules, Section 33 cross-border restriction
A legal limit on sending personal data out of a jurisdiction, usually conditioned on consent, contract, an adequacy finding or a statutory whitelist; Singapore, Hong Kong, Japan and India each structure the condition differently.
- APEC Privacy Framework
- Related: APEC Cross-Border Privacy Rules (CBPR) System, APEC information privacy principles
A non-binding framework agreed in APEC, first issued in 2004 and revised in 2015, containing nine information privacy principles meant to harmonise protection across member economies without obstructing trade.
- APEC Cross-Border Privacy Rules (CBPR) System
- Related: APEC Privacy Framework, Accountability Agent, Privacy Recognition for Processors (PRP)
A voluntary certification scheme in which an organisation's privacy practices are assessed against the APEC Framework by an approved Accountability Agent, enabling easier data flows between participating economies.
- Privacy Recognition for Processors (PRP)
- Related: APEC Cross-Border Privacy Rules (CBPR) System, Accountability Agent
An APEC certification for organisations that process data on behalf of others, showing controllers in participating economies that the processor meets recognised privacy standards.
- Accountability Agent
- Related: APEC Cross-Border Privacy Rules (CBPR) System
An independent body approved by an APEC economy that assesses organisations seeking CBPR or PRP certification, monitors their compliance and handles complaints about certified organisations.
- APEC information privacy principles
- Related: APEC Privacy Framework, APEC Cross-Border Privacy Rules (CBPR) System
The nine principles at the heart of the APEC Framework: preventing harm, notice, collection limitation, uses of personal information, choice, integrity, security safeguards, access and correction, and accountability.
- Singapore Personal Data Protection Act (PDPA)
- Related: Personal Data Protection Commission (PDPC), Deemed consent, Do Not Call Registry
Singapore's 2012 statute regulating collection, use and disclosure of personal data by private organisations; it created the Do Not Call regime and the PDPC, and was substantially amended in 2020.
- Personal Data Protection Commission (PDPC)
- Related: Singapore Personal Data Protection Act (PDPA), Data breach notification (Singapore)
Singapore's regulator for the PDPA, a unit of the Infocomm Media Development Authority, which issues advisory guidelines, investigates breaches and can impose financial penalties on organisations.
- Do Not Call Registry
- Related: Singapore Personal Data Protection Act (PDPA)
The Singapore registry of telephone numbers whose owners have opted out of telemarketing; sending specified messages to a registered number without clear consent is a breach of the PDPA.
- Deemed consent
- Related: Legitimate interests exception, Singapore Personal Data Protection Act (PDPA)
A PDPA concept where consent is inferred without an express statement - through conduct in providing data, contractual necessity, or notification with an easy opt-out - rather than being positively given.
- Legitimate interests exception
- Related: Deemed consent
A PDPA exception permitting processing without consent where an organisation has a legitimate interest that outweighs likely harm, subject to documented assessment and an obligation to inform individuals.
- Data Protection Officer
- Related: Singapore Personal Data Protection Act (PDPA), Personal Data Protection Commission (PDPC)
A person appointed by an organisation to oversee PDPA compliance, whose business contact details must be made public, and to whom data protection queries and complaints are directed.
- Data breach notification (Singapore)
- Related: Personal Data Protection Commission (PDPC)
The PDPA duty, effective from 1 February 2021, to notify the PDPC within three calendar days of determining that a breach is notifiable, and affected individuals where significant harm is likely.
- Personal Data (Privacy) Ordinance (PDPO)
- Related: Six Data Protection Principles, Privacy Commissioner for Personal Data (PCPD)
Hong Kong's Personal Data (Privacy) Ordinance, in force since 1995, which applies to personal data held by public and private organisations and sets six Data Protection Principles plus marketing and access rules.
- Six Data Protection Principles
- Related: Personal Data (Privacy) Ordinance (PDPO), Data access request
The six core obligations in Hong Kong's PDPO: lawful and fair collection with minimal data, accuracy and retention limits, purpose limitation, security, openness, and access and correction rights.
- Privacy Commissioner for Personal Data (PCPD)
- Related: Personal Data (Privacy) Ordinance (PDPO), Anti-doxxing provisions
Hong Kong's independent statutory office that promotes and enforces the PDPO, publishes codes of practice and guidance, and investigates complaints about data users.
- Data access request
- Related: Personal Data (Privacy) Ordinance (PDPO), Six Data Protection Principles
A request by a data subject in Hong Kong for a copy of personal data held about them; the data user must comply within 40 days unless a statutory exemption applies.
- Direct marketing rules under the PDPO
- Related: Personal Data (Privacy) Ordinance (PDPO), Do Not Call Registry
Part 6A of the PDPO requires written consent and a response facility before personal data is used or supplied for direct marketing, with criminal liability for non-compliance.
- Section 33 cross-border restriction
- Related: Personal Data (Privacy) Ordinance (PDPO), Cross-border data transfer restriction
The never-implemented PDPO provision that would require Hong Kong data users to ensure offshore transfers receive protection comparable to the Ordinance, or fall within a specified exemption.
- Anti-doxxing provisions
- Related: Personal Data (Privacy) Ordinance (PDPO), Privacy Commissioner for Personal Data (PCPD)
The 2021 amendments that created offences for disclosing personal data without consent intending to cause harm, and gave the Commissioner powers to demand cessation and investigate doxxing.
- Digital Personal Data Protection Act 2023
- Related: Data Fiduciary, Data Principal, Data Protection Board of India
India's 2023 statute for digital personal data, replacing the SPDI Rules framework; it sets obligations for Data Fiduciaries, rights for Data Principals and establishes the Data Protection Board.
- Data Fiduciary
- Related: Data Principal, Significant Data Fiduciary, Consent Manager
Under the DPDP Act 2023, the person that determines the purpose and means of processing digital personal data, and carries duties of notice, consent, security and breach reporting.
- Data Principal
- Related: Data Fiduciary, Consent Manager
The DPDP Act 2023 term for the individual whose digital personal data is processed, holding rights of access, correction, erasure and grievance redress; for children, a parent or guardian acts.
- Significant Data Fiduciary
- Related: Data Fiduciary, Data Protection Board of India
A Data Fiduciary designated by the Indian government based on data volume, sensitivity and risk, attracting extra duties such as an India-based data protection officer, audits and impact assessments.
- Data Protection Board of India
- Related: Digital Personal Data Protection Act 2023, Significant Data Fiduciary
The adjudicating body created by the DPDP Act 2023, which hears complaints, orders remedial action and imposes financial penalties for breaches of the Act.
- SPDI Rules 2011
- Related: Section 43A of the IT Act, Digital Personal Data Protection Act 2023
Indian rules under section 43A of the IT Act governing sensitive personal data such as passwords, financial information and health data; they were largely superseded by the DPDP Act 2023.
- Section 43A of the IT Act
- Related: SPDI Rules 2011
An Indian IT Act provision making a body corporate liable to compensate affected persons for negligent failure to maintain reasonable security practices for sensitive personal data, now repealed by the DPDP Act.
- Consent Manager
- Related: Data Principal, Data Fiduciary
A person registered with India's Data Protection Board who acts as a single point for a Data Principal to give, manage, review and withdraw consent across different Data Fiduciaries.
- Act on the Protection of Personal Information (APPI)
- Related: Personal Information Protection Commission (PPC), Special care-required personal information, APPI cross-border transfer rules
Japan's statute governing business handling of personal information; it defines special categories, regulates third-party provision and cross-border transfer, and is supervised by the Personal Information Protection Commission.
- Personal Information Protection Commission (PPC)
- Related: Act on the Protection of Personal Information (APPI)
Japan's independent administrative commission that oversees APPI compliance, issues guidelines, handles complaints, and may issue recommendations and orders to businesses.
- Special care-required personal information
- Related: Act on the Protection of Personal Information (APPI), Opt-out third-party provision
The APPI category for sensitive data such as race, creed, social status, medical history, criminal record and disability, which generally requires explicit consent and extra safeguards.
- Individual identification code
- Related: Act on the Protection of Personal Information (APPI), Pseudonymised processed information
An APPI concept covering identifiers like passport numbers, biometric templates and My Number that single out an individual, treated as personal information even without a name.
- Opt-out third-party provision
- Related: Special care-required personal information, APPI cross-border transfer rules
An APPI route allowing data to be supplied to third parties without consent where the business notifies the PPC and the individual in advance and provides an easy opt-out; sensitive data is excluded.
- Pseudonymised processed information
- Related: Individual identification code, Act on the Protection of Personal Information (APPI)
Information produced by processing personal data so that specific individuals cannot be identified unless matched with other data; the APPI relaxes some rules but restricts third-party provision.
- APPI cross-border transfer rules
- Related: Act on the Protection of Personal Information (APPI), APEC Cross-Border Privacy Rules (CBPR) System
Japan's rules on transfers to foreign third parties: prior consent is generally required unless the destination is on the PPC's adequate list or the recipient maintains equivalent standards, such as APEC CBPR certification.