PDPA Review and DPO Duty Assessment

Illustrative preparation, not evidence of our staff, clients or an actual approval.
ตรวจ PDPA และประเมินหน้าที่ DPO · § Compliance
Quick Answer
Map customer, employee, system and vendor data before prioritising risks. Assess a legal basis for each purpose rather than requiring consent everywhere. Review processing records, processor agreements, overseas transfers and breach response. A review identifies gaps and remediation; it is not immunity certification.
Typical timeline (not guaranteed): Prioritise by systems, risk and operational remediation. Review, documentation and system changes have different schedules and require ongoing reassessment; no fixed weeks-to-compliance promise is made. — depends on government queues; we confirm it in writing after reviewing your documents.
Official fee: An internal review is not an application for PDPA approval certification. Penalties are not service filing fees. Check relevant procedures with PDPC. Ask our team for a quotation.
What to send for a quotation
Send system and purpose inventories and current policies, not entire live customer datasets through enquiries. Identify a coordinator and any urgent incident. The free initial enquiry covers scope and quotation, not free legal advice.
Legal Basis
The PDPA imposes duties according to controller or processor roles and actual processing. Review legal bases, sensitive data, notices, rights and security measures. DPO duties depend on the Act and applicable notifications, not a universal 10,000-record threshold or business label. Qualifying breaches must be notified to the Office without delay and, where feasible, within 72 hours of awareness, subject to risk criteria and current rules.
📚 Official sources — verify current requirements before acting
Who Needs This
Organisations reviewing employee data and access
Required Documents
- Data categories and processing purposes
- Collection, transfer, retention and deletion flows
- Privacy notices and legal-basis evidence
- Vendor and processor contracts
- Rights, breach and DPO-assessment procedures
Common Pitfalls
- Assuming documents or DPO appointment satisfy all duties
- Using consent without assessing suitability
- Assuming all overseas transfers require one mechanism
- Waiting for a complaint letter before assessing a breach
Preparation situations (not client histories)
- Organisations reviewing employee data and access
- Online shops separating order fulfilment from marketing
- Multinationals assessing recipients and overseas transfers
FAQ
- Does every company need a DPO?
- No. Assess Section 41 and relevant notifications against actual roles and activities, not one record-count threshold.
- Must a breach be reported within 72 hours?
- Where notification is required, inform the Office without delay and where feasible within 72 hours of awareness. Assess risk and data-subject notification duties; not every incident is handled identically.
- Is a Privacy Notice sufficient?
- Not automatically. Review actual practice, legal bases, rights, security, recipients and applicable duties.
- Does timely remediation guarantee only a warning?
- No. Read the notice deadline, preserve evidence and assess the response and remediation for the facts. Do not apply a fixed 30-day period universally.
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