The Ninja Sensei’s Logbook: Understanding the Transfer Limitation Obligation

The Transfer Limitation Obligation is one of the Obligations under the PDPA Law in Singapore. Non-compliance is an offence and may be chargeable.

The PDPA covers a wide range of obligations for organisations that handle personal data to follow. This is to ensure that all aspects in handling such data are covered, even when transferring it overseas.

The 𝐓𝐫𝐚𝐧𝐬𝐟𝐞𝐫 𝐋𝐢𝐦𝐢𝐭𝐚𝐭𝐢𝐨𝐧 𝐎𝐛𝐥𝐢𝐠𝐚𝐭𝐢𝐨𝐧 covers this and restricts organisations from transferring personal data to a country or territory outside of Singapore unless it complies with requirements prescribed by the PDPA.

Based on the PDPA, an organisation may transfer personal information abroad if:

👉 While the transferred personal data is in its custody or control, the organisation has taken the necessary precautions to ensure that the personal data will be treated securely and in accordance with the Data Protection Provisions.
👉 The recipient is located in a country or territory outside of Singapore and is obligated by legally enforceable responsibilities to provide to the personal data transferred a quality of protection that is comparable to that under the Personal Data Protection Act (PDPA) of Singapore.

𝐖𝐡𝐚𝐭 𝐝𝐨𝐞𝐬 𝐭𝐡𝐢𝐬 𝐦𝐞𝐚𝐧 𝐭𝐨 𝐨𝐫𝐠𝐚𝐧𝐢𝐬𝐚𝐭𝐢𝐨𝐧𝐬?
This means that before an organisation can transfer personal data to a recipient that is located outside Singapore, they must first ensure that they have obliged with the conditions set by the PDPA and see to it that the recipient has enforced protection to the transferred data that is comparable to Singapore’s data protection law.

𝐖𝐡𝐚𝐭 𝐡𝐚𝐩𝐩𝐞𝐧𝐬 𝐰𝐡𝐞𝐧 𝐢𝐭 𝐢𝐬 𝐛𝐫𝐞𝐚𝐜𝐡𝐞𝐝?
Like any other obligation under the PDPA that is breached, the organisation suffers not only the potential hefty financial penalty set by the PDPC but also the loss of confidence from its customers, which could discourage other future clients from trusting your organisation.

P.S. For any further questions or if you need help with your cybersecurity and data protection compliance journey, don’t hesitate to reach out to us. At Privacy Ninja, We are always a text/call or email away!

📱 WhatsApp: +65 8750 4250
📧 Email:

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