SG PDPA PDPA Section 4(2)
Data intermediaries processing children's data on behalf of organisations must comply with protection and retention obligations; the principal organisation remains accountable
Where this comes from
Provision: PDPA Section 4(2); PDPC Advisory Guidelines, Section 6 - Data Intermediaries
Instrument: Singapore Personal Data Protection Act (PDPA)
Citation: Personal Data Protection Act 2012 (No. 26 of 2012), Section 4(2) (Data Intermediary Definition); PDPC Advisory Guidelines on Key Concepts in the PDPA, Section 6; PDPC Advisory Guidelines on Children's Personal Data (March 2024), Sections 6.1-6.5
Text version: PDPA 2012 (2020 Rev. Ed.); PDPC Advisory Guidelines on Children's Personal Data (2024)
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
- Third-party data sharing is all collected data or Some categories only
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Data-intermediary relationships are governed by a contract defining the processing scope
- The intermediary meets the Protection Obligation and Retention Limitation Obligation under the PDPA
- Safeguards for children's data are commensurate with its sensitivity
- The principal organisation's continuing accountability and oversight of the intermediary are documented
- System handles null/empty input gracefully (no 500 errors)
Questions people ask
- Does SG PDPA PDPA Section 4(2) apply to my service?
- It applies when Service is likely to be accessed by children under 18; Third-party data sharing is all collected data or Some categories only.
- From when does this apply?
- SG PDPA PDPA Section 4(2) applies from 1 March 2024. Its current status is: in force.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.