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Data Transfer Addendum

Data Transfer Addendum Template for Singapore

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Key Requirements PROMPT example:

Data Transfer Addendum

"I need a Data Transfer Addendum for transferring customer data from our Singapore headquarters to our new data processing center in India, ensuring compliance with PDPA and including specific provisions for healthcare data security."

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What is a Data Transfer Addendum?

The Data Transfer Addendum is essential when organizations need to transfer personal data within or outside of Singapore. It supplements existing agreements by specifically addressing data protection requirements under Singapore's PDPA and related regulations. This document is particularly crucial in light of increasing global data protection requirements and cross-border data flows. The addendum details the obligations of both parties, security measures, breach notification procedures, and compliance requirements for safe and lawful data transfers.

What sections should be included in a Data Transfer Addendum?

1. Parties: Identification of data exporter and data importer, including full legal names and registration details

2. Background: Context of the data transfer relationship and reference to main agreement

3. Definitions: Key terms including Personal Data, Processing, Transfer, Security Measures, etc.

4. Scope and Purpose of Transfer: Details of data categories, transfer purposes, and processing activities

5. Data Protection Obligations: Core obligations under PDPA including consent, protection, and retention requirements

6. Security Measures: Technical and organizational measures for data protection

7. Data Breach Notification: Procedures and timelines for reporting data breaches

What sections are optional to include in a Data Transfer Addendum?

1. Sub-processor Provisions: Rules for appointment and oversight of sub-processors when data importer may engage third parties for processing

2. Industry-Specific Compliance: Additional requirements for specific regulated industries such as finance, healthcare, etc.

3. Data Subject Rights: Procedures for handling data subject requests, particularly when transfers involve EU data subjects or GDPR compliance

What schedules should be included in a Data Transfer Addendum?

1. Schedule 1 - Description of Transfer: Detailed description of data categories, subjects, and processing purposes

2. Schedule 2 - Technical and Security Measures: Detailed security requirements and controls

3. Schedule 3 - Sub-processors: List of approved sub-processors and their roles

4. Schedule 4 - Transfer Impact Assessment: Assessment of risks and safeguards for cross-border transfers

Authors

Alex Denne

Head of Growth (Open Source Law) @ 黑料视频 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
Relevant legal definitions



























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Industries

PDPA_2012: Singapore's Personal Data Protection Act 2012 - Primary legislation governing personal data protection in Singapore

PDPA_Regulations_2021: Personal Data Protection Regulations 2021 - Detailed regulatory requirements supplementing the PDPA

PDPA_Guidelines: Advisory Guidelines issued by PDPC providing practical guidance on PDPA implementation

Cybersecurity_Act_2018: Singapore's Cybersecurity Act establishing framework for protection of critical information infrastructure

APEC_CBPR: APEC Cross-Border Privacy Rules System - Regional framework for data protection and transfer

ASEAN_Framework: ASEAN Framework on Personal Data Protection - Regional principles for data protection

APPA_Guidelines: Asia-Pacific Privacy Authorities Forum Guidelines for cross-border data protection

GDPR_Considerations: EU General Data Protection Regulation considerations if transfers involve EU data subjects

PIPL_Considerations: China's Personal Information Protection Law considerations for transfers involving Chinese data subjects

Consent_Obligation: PDPA requirement to obtain valid consent for collection, use, and disclosure of personal data

Purpose_Limitation: PDPA obligation to collect, use or disclose personal data only for reasonable purposes

Notification_Obligation: PDPA requirement to inform individuals of the purpose for collecting, using, and disclosing their personal data

Protection_Obligation: PDPA requirement to implement security arrangements to protect personal data

Retention_Limitation: PDPA obligation to cease retention of personal data when no longer necessary for legal or business purposes

Transfer_Limitation: PDPA requirements for transferring personal data outside of Singapore

Accuracy_Obligation: PDPA requirement to make reasonable effort to ensure personal data collected is accurate and complete

Access_Correction: PDPA obligations regarding individual rights to access and correct their personal data

Industry_Guidelines: Sector-specific requirements including financial sector and healthcare sector guidelines

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks, 聽Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination, 聽Severance Pay, Governing Law, Entire Agreemen

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