Marketing Emails The Spam Control Act or SCA
267 governs unsolicited commercial communications sent in bulk via electronic mail. Concerning personal data,
anyone who receives an unsubscribe request in connection with the sending of an
unsolicited commercial electronic message shall not disclose any information
contained in such request to any other person, except with the consent of the person
whose particulars are contained in the unsubscribe request.
268
As of 27 April 2018, the Commission was considering a merger of the DNC
Provisions of the PDPA and the Spam Control Act under a single act governing
“unsolicited commercial messages”.
269 This follows similar approaches in jurisdictions such as Hong Kong and the United Kingdom.
270
3.7.3 Electronic Communications Sector
The PDPA applies generally to the electronic communications sector (see Sect. 2.1).
In addition, the Telecommunications Act
271 and the Electronic Transactions Act or
ETA
272 (both also administered by the IMDA) touch on certain aspects of personal
data protection.
The Commission’s guidelines specifically provide some examples of the PDPA
as applied to the telecommunications sector.
273 For instance, the guidelines discuss
what may constitute “personal data” in the telecommunications context: e.g. an
individual’s mobile telephone number and, if combined with other information, an
Internet Protocol (“IP”) address and International Mobile Equipment Identity
(“IMEI”) numbers.
274
Second, under the Telecommunications Act, a public telecommunication licensee
has no liability to anyone due to “any loss of secrecy in communication arising from
the use of any telecommunication service” due to “the act or default of another
person, or an accident or some other cause” beyond the licensee’s control.
275 More
specifically with regard to personal data, the act also “sets out certain purposes for
which telecommunication operator[s] may collect, use or disclose End User Service
267 See n 17. The SCA is administered by the IMDA.
268 SCA s 11 read with Second Schedule s 2(8).
269 PDPC Combined Regime Proposal 2018.
270 PDPC Combined Regime Proposal 2018.
271 See n 18.
272 See n 13.
273 PDPC Advisory Guidelines for the Telecommunication Sector.
274 PDPC Advisory Guidelines for the Telecommunication Sector paras 2.4–2.5. Thus, when a
Singapore telecommunications operator provider exchanges personal data with a foreign telecommunications operator to allow the latter to provide mobile services to outbound roamers who are
subscribers of the Singapore operator, the Singapore operator will need to comply with the
Notification, Consent and Limited Transfer Obligations. PDPC Advisory Guidelines for the
Telecommunication Sector para 3.7. See also Sects. 2 and 4.2.
275 Telecommunications Act s 70(d).
Singapore Report: Data Protection in the Internet
335
267 governs unsolicited commercial communications sent in bulk via electronic mail. Concerning personal data,
anyone who receives an unsubscribe request in connection with the sending of an
unsolicited commercial electronic message shall not disclose any information
contained in such request to any other person, except with the consent of the person
whose particulars are contained in the unsubscribe request.
268
As of 27 April 2018, the Commission was considering a merger of the DNC
Provisions of the PDPA and the Spam Control Act under a single act governing
“unsolicited commercial messages”.
269 This follows similar approaches in jurisdictions such as Hong Kong and the United Kingdom.
270
3.7.3 Electronic Communications Sector
The PDPA applies generally to the electronic communications sector (see Sect. 2.1).
In addition, the Telecommunications Act
271 and the Electronic Transactions Act or
ETA
272 (both also administered by the IMDA) touch on certain aspects of personal
data protection.
The Commission’s guidelines specifically provide some examples of the PDPA
as applied to the telecommunications sector.
273 For instance, the guidelines discuss
what may constitute “personal data” in the telecommunications context: e.g. an
individual’s mobile telephone number and, if combined with other information, an
Internet Protocol (“IP”) address and International Mobile Equipment Identity
(“IMEI”) numbers.
274
Second, under the Telecommunications Act, a public telecommunication licensee
has no liability to anyone due to “any loss of secrecy in communication arising from
the use of any telecommunication service” due to “the act or default of another
person, or an accident or some other cause” beyond the licensee’s control.
275 More
specifically with regard to personal data, the act also “sets out certain purposes for
which telecommunication operator[s] may collect, use or disclose End User Service
267 See n 17. The SCA is administered by the IMDA.
268 SCA s 11 read with Second Schedule s 2(8).
269 PDPC Combined Regime Proposal 2018.
270 PDPC Combined Regime Proposal 2018.
271 See n 18.
272 See n 13.
273 PDPC Advisory Guidelines for the Telecommunication Sector.
274 PDPC Advisory Guidelines for the Telecommunication Sector paras 2.4–2.5. Thus, when a
Singapore telecommunications operator provider exchanges personal data with a foreign telecommunications operator to allow the latter to provide mobile services to outbound roamers who are
subscribers of the Singapore operator, the Singapore operator will need to comply with the
Notification, Consent and Limited Transfer Obligations. PDPC Advisory Guidelines for the
Telecommunication Sector para 3.7. See also Sects. 2 and 4.2.
275 Telecommunications Act s 70(d).
Singapore Report: Data Protection in the Internet
335