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Record STMT-W173730Advisory

Advisory Guidelines on Use of Personal Data in Generative AI

ADVISORY GUIDELINES ON USE OF PERSONAL DATA IN GENERATIVE AI

Guidelines State lawSouth-eastern Asia · SGin force

These advisory guidelines clarify how Singapore's Personal Data Protection Act (PDPA) applies to the development and deployment of generative AI models and systems. They cover exceptions for publicly available data, notification and consent requirements, data protection responsibilities across the AI lifecycle (for model providers, system providers, and system deployers), and the handling of individual access and correction requests.

Summary and content fields are drawn from the document text and are pending editorial review.

Who issued it

Personal Data Protection CommissionRegulator · SG
Lead issuer
Legal forceAdvisory
Under whose authorityState law
Judged fromfull text

Who it governs

RegulatorsPublic sector bodiesCompaniesAI developers and providersAI deployers and usersResearchers and academics

Organisations, model providers, system providers, system deployers, and data intermediaries seeking guidance on complying with data protection laws when developing and deploying generative AI.

Sectors
Cross-sectorTelecommunications and digital services · Generative AI systems and models

What the document contains

What's covered

The document addresses the collection and use of personal data for developing generative AI models, the allocation of data protection responsibilities across the AI lifecycle for model providers, system providers, and system deployers, and the handling of individual access and correction requests under Singapore's PDPA.

What's missing

The guidelines are advisory in nature, are not legally binding, and do not modify or supplement the legal interpretation of the PDPA or any subsidiary legislation.

Key takeaways
  • The advisory guidelines clarify how the Personal Data Protection Act (PDPA) applies specifically to generative AI models and systems.
  • Organisations may rely on the Publicly Available Exception for web-scraped training data under certain conditions, though digital barriers and contractual terms must be assessed.
  • General notifications are insufficient for training generative AI on user data; organisations must provide AI-specific notifications with clear details on how data is used.
  • Generative AI stakeholders—including model providers, system providers, and system deployers—have distinct data protection obligations depending on whether they act as organisations or data intermediaries.
  • Organisations are expected to navigate technical challenges regarding individual access and correction requests by adopting upstream data handling, case-by-case reviews, and emerging technical removal measures.
Outline
· PART I: INTRODUCTION AND SCOPE
  - 1 Introduction
  - 2 Scope of the Guidelines
· PART II: DEVELOPMENT – COLLECTING AND USING PERSONAL DATA TO DEVELOP GENERATIVE AI MODELS
  - 3 Publicly Available Exception
  - 4 Consent and Notification Obligations
  - 5 Additional Considerations
· PART III: DEPLOYMENT - DATA PROTECTION RESPONSIBILITIES OF GENERATIVE AI STAKEHOLDERS
  - 6 Generative AI Stakeholders
  - 7 Model Providers
  - 8 System Providers
  - 9 System Deployers
· PART IV: POST DEPLOYMENT - ADDRESSING INDIVIDUAL REQUESTS ABOUT PERSONAL DATA
  - 10 Access and Correction Obligations
Issued20 July 2026
Length6,020 words · 18 pages
FormatNot recorded
Scopenational

How it scores

Pending review

Each score is backed by a quote verified against the document text. Editorial review has not yet confirmed them.

Fairness

0/5

Non-discrimination and equitable treatment

screening score · 2026-10-23

Human Dignity

0/5

Respect for the inherent worth of persons

screening score · 2026-10-23

Human Oversight

4/5

Humans remain in control of consequential decisions

• Introducing escalating protocols to humans for complex or high-risk tasks.

Section 9.5 Example

screening score · 2026-10-23

Transparency

4/5

Openness about how AI systems work and are used

Organisations must provide AI-Specific Notifications for this purpose. The key purpose of the Consent and Notification Obligations is to enable individuals to provide meaningful consent.

Section 4.4

screening score · 2026-10-23

Enforcement

4/5

Consequences and compliance mechanisms with real force

If the Commission require s the organisation to justify its reliance on the Publicly Available Exception, it must produce this documentation.

Section 3.7

screening score · 2026-10-23

Topics

data_protection generative_ai consent privacy compliance