With the 2024 and 2025 updates to the Personal Data Protection Act 2010 (PDPA), organisations in Malaysia now face stricter expectations of accountability and personal data governance.
To help, we have prepared a practical framework for implementing PDPA compliance.
7 core personal data protection principles
The foundation of PDPA compliance lies upon seven core principles that collectively govern how personal data is collected, used, stored, and disclosed.
| Principle | What It Means | Example |
| General Principle | Only collect personal data when necessary and with consent | Don’t collect NRIC numbers if just names and emails will do |
| Notice and Choice Principle | Inform individuals of what personal data you collect and how it will be used. | Include a clear privacy notice on your website or registration form |
| Disclosure Principle | Don’t disclose personal data without consent, unless required by law or is necessary | Obtain written consent before sharing a client’s details with a third-party service provider (e.g., marketing agency) |
| Security Principle | Protect personal data from loss, misuse, or unauthorised access | Use password protection and encryption for databases storing customer details |
| Retention Principle | Don’t keep personal data longer than necessary | Delete job application forms and candidate records after a certain duration (such as 12 months after the hiring process concludes) |
| Data Integrity Principle | Ensure personal data is accurate, complete, and up to date | Regularly verify contact details for existing customers in your CRM |
| Access Principle | Individuals have the right to access and correct their personal data | Provide customers a way to view or update personal info |
Organisations should apply these into their daily operations, policies, and data lifecycle processes.
A PDPA-compliant privacy notice
Whether on your website, registration form, or physical premises, a clear and accessible privacy notice is a great first step for organisations to demonstrate the above PDPA principles in action to individuals whose personal data they collect.
Ensure the notice is easy to find, written in both Bahasa Malaysia and English, and clearly explains:
- what data you collect (e.g. name, IC number, mail, contact details)
- why you collect it (e.g. for billing, support, or marketing)
- where the data comes from (e.g. online forms, emails, or third parties)
- who you may share it with (e.g. delivery partners, payment processors)
- how individuals can access or correct their data
- whether providing the data is optional or required, and what happens if they don’t
- what choices individuals have (e.g. opting out of marketing)
Under the Notice and Choice Principle, this should be done as early as possible, ideally when someone is first asked for their data or when it’s collected.
Building a practical compliance framework
While privacy notices are a good first step, true compliance is only achieved when organisations have built a company-wide culture where personal data protection is embedded into every part of daily operations.
This means having the right systems, processes, and people in place, and here’s a practical framework to move towards it:
- PDPA Training: Train employees, especially those in HR, marketing, customer service, and IT, on your organisation’s personal data protection responsibilities, PDPA requirements, and how to act accordingly in their day-to-day work.
- Data Protection Manual: Develop a practical manual outlining roles, controls, and escalation procedures to ensure employees across departments know how to handle personal data.
- Internal Compliance Audit: Conduct internal reviews to identify gaps, assess risks, and benchmark practices against PDPA obligations.
- External Data Protection Audit: Carried out by legal consultants, privacy professionals, or external auditors who assess how well your organisation is complying with the PDPA, identify compliance gaps, and provide clear recommendations to fix them.
- Data Protection Impact Assessment (DPIA): DPIAs are used to assess and mitigate potential risks arising from personal data processing activities, especially when handling sensitive or large volumes of personal data.
- Appoint a Data Protection Officer (DPO): For organisations that meet the DPO appointment threshold or those handling significant volumes of personal data, designating a DPO ensures accountability. The DPO helps oversee compliance, advise teams, and liaise with regulators if needed.
For a better understanding of who qualifies as DPO or how to appoint one, check out our guides on:
Scaling PDPA efforts to business size
Matching PDPA efforts to your organisation’s capacity, complexity, and data risk is key to sustainability.
Start with the most essential, reassess priorities and expand step-by-step.
Smaller / newer enterprises
Start with the essentials:
- know the 7 key principles and what they mean for your business
- put together a simple privacy notice and core policies
- have a basic breach response plan so everyone is aligned on what to do
Larger / established businesses
At this stage, PDPA compliance should be embedded in your business functions:
- appoint a DPO to oversee data governance, policies, training, and audits across departments
- develop structured breach response protocols involving legal and IT
- run regular audits with internal teams and external consultants to identify security gaps
- roll out organisation-wide training with regular PDPA onboarding and refresher sessions
Not every organisation needs to take the same path, but all paths should lead to the same outcome.
Conclusion
Compliance with the PDPA is a continuous journey and embedding PDPA principles into your business practices lays the foundation for building trust, reducing risk, and staying compliant with changing regulatory expectations.
If you need help putting it into action, we are here to support you with reviewing your current setup, drafting policies, or building a full compliance framework tailored to your needs.
