the individual’s name, residential address, email address, telephone number, date of birth,
national registration identity card number, passport number, signature (whether handwritten
or electronic) or password.
246
This bill also acknowledges that many of these publications take place electronically: where the information is published online, the court may also require the
platform provider to disable access to the offending publication.
247
POFMA
POFMA is intended to (among other things) prevent electronic communication in
Singapore of false statements of fact; such statements could presumably include
personal data. It will be an offence to do any act (whether in or outside Singapore), in
order to communicate a statement, knowing or having reason to believe that it is
false, where: the communication of such statement is likely to be prejudicial to
Singapore’s security, to public health, or Singapore’s friendly relations to other
countries; or will incite feelings of enmity between different groups of persons.
248
This includes any statements made using “inauthentic online accounts” or “bots”.
249
3.7.2 Marketing
IP Addresses; Cookies If they can identify individuals, IP addresses and cookies
may be considered personal data, and therefore subject to the PDPA.
250 However,
there may not be a need to seek consent for the use of cookies to collect, use or
disclose personal data where the individual involved is aware of the purposes for
such collection, use or disclosure and has voluntarily provided his personal data for
such purposes (e.g. for transmitting personal data for effecting online communications, and storing information that the user enters in a web form to facilitate an online
purchase).
251
For activities that cannot take place without cookies, consent may be deemed if
the individual voluntarily provides the personal data for that purpose of the activity
and it is reasonable that he would do so.
252
“Consent may also be reflected in the way
a user configures his interaction with the Internet”, e.g. if he/she configures his
browser “to accept certain cookies but rejects others”.
253 However, an individual’s
failure to actively manage his/her browser settings does not imply consent to the
246 No 11/2019 s 3.
247 No 11/2019 s 16.
248 POFMA s 7(1).
249 POFMA s 7(3).
250 PDPC Advisory Guidelines for Selected Topics paras 6.1–6.3, 6.6.
251 PDPC Advisory Guidelines for Selected Topics para 6.8.
252 PDPC Advisory Guidelines for Selected Topics para 6.8.
253 PDPC Advisory Guidelines for Selected Topics para 6.9.
Singapore Report: Data Protection in the Internet
333
national registration identity card number, passport number, signature (whether handwritten
or electronic) or password.
246
This bill also acknowledges that many of these publications take place electronically: where the information is published online, the court may also require the
platform provider to disable access to the offending publication.
247
POFMA
POFMA is intended to (among other things) prevent electronic communication in
Singapore of false statements of fact; such statements could presumably include
personal data. It will be an offence to do any act (whether in or outside Singapore), in
order to communicate a statement, knowing or having reason to believe that it is
false, where: the communication of such statement is likely to be prejudicial to
Singapore’s security, to public health, or Singapore’s friendly relations to other
countries; or will incite feelings of enmity between different groups of persons.
248
This includes any statements made using “inauthentic online accounts” or “bots”.
249
3.7.2 Marketing
IP Addresses; Cookies If they can identify individuals, IP addresses and cookies
may be considered personal data, and therefore subject to the PDPA.
250 However,
there may not be a need to seek consent for the use of cookies to collect, use or
disclose personal data where the individual involved is aware of the purposes for
such collection, use or disclosure and has voluntarily provided his personal data for
such purposes (e.g. for transmitting personal data for effecting online communications, and storing information that the user enters in a web form to facilitate an online
purchase).
251
For activities that cannot take place without cookies, consent may be deemed if
the individual voluntarily provides the personal data for that purpose of the activity
and it is reasonable that he would do so.
252
“Consent may also be reflected in the way
a user configures his interaction with the Internet”, e.g. if he/she configures his
browser “to accept certain cookies but rejects others”.
253 However, an individual’s
failure to actively manage his/her browser settings does not imply consent to the
246 No 11/2019 s 3.
247 No 11/2019 s 16.
248 POFMA s 7(1).
249 POFMA s 7(3).
250 PDPC Advisory Guidelines for Selected Topics paras 6.1–6.3, 6.6.
251 PDPC Advisory Guidelines for Selected Topics para 6.8.
252 PDPC Advisory Guidelines for Selected Topics para 6.8.
253 PDPC Advisory Guidelines for Selected Topics para 6.9.
Singapore Report: Data Protection in the Internet
333