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Controller To Controller DPA Template for Singapore

A Controller-to-Controller Data Processing Agreement under Singapore law establishes the terms and conditions for sharing personal data between two independent data controllers. This agreement ensures compliance with Singapore's Personal Data Protection Act (PDPA) and related regulations, defining responsibilities for data protection, security measures, breach notifications, and cross-border transfers where applicable. It provides a framework for lawful data sharing while maintaining data protection standards.

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What is a Controller To Controller DPA?

The Controller to Controller DPA is essential when two organizations acting as independent data controllers need to share personal data in Singapore. This agreement type is particularly important under Singapore's PDPA framework, which requires organizations to implement appropriate data protection measures when handling personal data. The document outlines specific responsibilities, security requirements, breach notification procedures, and compliance obligations for both controllers, ensuring lawful and secure data sharing practices while maintaining individual privacy rights.

What sections should be included in a Controller To Controller DPA?

1. Parties: Identification and details of both data controllers

2. Background: Context of the data sharing arrangement and references to key Singapore legislation including PDPA

3. Definitions: Key terms used throughout the agreement including PDPA-specific terminology

4. Purpose and Scope: Specific purposes for which personal data will be shared and scope of processing activities

5. Data Protection Obligations: Compliance with PDPA obligations by both parties including the Nine Data Protection Obligations

6. Security Measures: Technical and organizational measures for data protection in accordance with PDPA requirements

7. Data Breach Notification: Procedures for handling and reporting data breaches as per PDPA Regulations

8. Term and Termination: Duration of the agreement and termination provisions

What sections are optional to include in a Controller To Controller DPA?

1. Cross-border Transfers: Provisions for international data transfers in compliance with PDPA and ASEAN Framework requirements

2. Sub-processing: Terms and conditions for engaging sub-processors by either controller

3. Industry-Specific Requirements: Additional requirements for specific regulated sectors under Singapore law

What schedules should be included in a Controller To Controller DPA?

1. Description of Processing: Detailed description of data processing activities and categories of personal data

2. Security Measures: Detailed technical and organizational security measures implemented by both parties

3. Approved Sub-processors: List of approved sub-processors and their processing activities

4. Data Transfer Mechanisms: Details of cross-border transfer mechanisms and safeguards

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok成人版 | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents

Jurisdiction

Singapore

Cost

Free to use

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