Singapore Releases New Personal Data Guidelines for AI Systems
On March 1, the Singapore Personal Data Protection Commission (PDPC) released the Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems. The Guidelines aim to provide organizations with greater clarity regarding when they can collect and use personal data to develop and deploy AI systems while remaining compliant with the Personal Data Protection Act (PDPA). While meaningful consent is normally needed for organizations to use personal data, the Guidelines outline criteria for exceptions to consent under the PDPA, including business improvement (e.g., product recommendations for consumers), research (e.g., precision medicine), and legitimate interest. Although the Guidelines are not legally binding, they provide greater insight as to how PDPC will position itself to enforce the PDPA in cases related to AI systems.
The Guidelines do not explicitly address generative AI systems. Instead, this is covered under Infocomm Media Development Authority’s Proposed Model AI Governance Framework for Generative AI. Announced in January 2024, it seeks to address emerging concerns, principles, and technological developments related to generative AI. Generative AI was highlighted again at the Committee of Supply 2024, where Minister for Communications and Information Josephine Teo shared that the PDPC is considering issuing additional guidance on the use of personal data to train generative AI systems.