Data Compliance Practice Guide (China & Singapore Chapter)

Asian Business Law Institute and Shenzhen Data Exchange (September 2025)

Please contact abli_info@abli.asia for queries relating to this publication. 

This bilingual guide, jointly developed by the Asian Business Law Institute and the Shenzhen Data Exchange, is authored by a team of leading data protection experts with vast practical and cross-border experience in China and Singapore. It provides a clear and practical framework to guide businesses to navigate relevant compliance requirements in the two countries, offering insights on key legal obligations, tailored best practices and actual case studies.

Written for businesses expanding across borders, the guide will be a valuable assistant to support companies in expanding confidently in the digital economy while managing risks and ensuring compliance.

Table of Content

China Chapter

Chapter 1 Overview and User Guide (pp 12)

Introduction: The Context of China–Singapore Digital Cooperation and the Value of the Guide 

China’s Practical Framework and Compliance Logic for Data Governance

Guidelines for Use and Practical Tools

Chapter II Regulatory System and Departmental Responsibilities (pp 23)

Cyberspace Administration of China (CAC)

Ministry of Industry and Information Technology (MIIT)

Public Security Authorities

Market Regulation Authorities

Industry Regulators and Other Authorities

National Data Security Coordination Mechanism

Chapter III Compliance Requirements for Data Processing Entities (PP 31)

Organizational Structure

Policy Development and Personnel Management

Data Classification and Grading

Management of External Partners

Risk Assessment Mechanisms

Security Incident Response and Handling

Chapter IV. Compliance Management Standards for Data Subject Matter (PP 46)

Common Requirements for General Data

Important Data

Personal Information

Public Data

Special Industry Data

Chapter V: Compliance Paths for Cross-Border Data Flow (PP 118)

Path Selection for Outbound Data Flow

Requirements for Data Processors in Outbound Data Flow

Localization Data Storage Requirements

Chapter VI: Good Compliance Practice Guidelines (PP 152)

Data Protection and Compliance Guide: Frequently Asked Questions (PP 164)

Annex 1: Glossary (PP 175)

Singapore Chapter

Introduction (PP 5)

Purpose of the Guide

Overview of the Singapore Data Regulatory Regime

Understanding the PDPA framework (PP 6)

Scope and Applicability

Key Principles of the PDPA

Key Compliance Obligations (PP 12)

Data Protection Officer: Qualifications and Responsibilities

Obtaining Consent for Processing and Marketing

Data Management Policies

Data Breach Management

Data Processing and Cross-Border Transfers

Enforcement and Penalties (PP 23)

Investigation powers of the PDPC

Power to issue directions to secure compliance

Financial Penalties

Voluntary Undertakings

Practical steps for Compliance (PP 25)

Challenges and Practical Solutions for Small Businesses

Challenges and Practical Solutions for Large Corporations

Specific Challenges for Chinese Companies (PP 28)

Appendices (PP 30)

Sample Checklists

Sample templates (e.g., sample consent forms or sample clauses)