Q1148. What data protection laws govern PDPA and GDPR compliance policy translations?

Answered by the NYC Visa & Translation certified translation team

PDPA and GDPR compliance documents are translated in both directions in Thai practice, and the laws' own language requirements drive the work. The Thai PDPA direction: Thailand's Personal Data Protection Act requires privacy notices to data subjects in Thai for Thai data subjects — a foreign company's global privacy policy must have a Thai version for its Thai operations, and the notice must be genuinely understandable (the PDPA's consent requirements mean a machine-translated notice that obscures the processing purposes can invalidate consent); the key content (data categories, purposes, legal bases, retention, data subject rights, contact for the DPO) must map to the PDPA's prescribed notice elements. The GDPR direction: Thai companies serving EU data subjects need GDPR-compliant notices in the relevant EU languages, with the English master text controlling the group's compliance framework. Points that matter: the two laws' concepts do not map perfectly (the PDPA's legal bases and the GDPR's differ in detail) — the translation must reflect each law's actual requirements, not force one framework's vocabulary onto the other; consent language is the highest-stakes text — the request for consent must be explicit, separate, and specific in each language; and data processing agreements, records of processing, and breach notification procedures follow the same translation discipline. Practice points: maintain a bilingual terminology glossary for the compliance program (the defined terms must be identical across the notice, the DPA, and the internal policies); and when the policies update, track which language version is the master and propagate changes systematically. Coordinate with data protection counsel on both texts before publication.