The Master Data Protection Agreement is essential for organizations operating in Singapore that engage in significant data processing activities. This agreement ensures compliance with Singapore's Personal Data Protection Act (PDPA) and related regulations while establishing clear guidelines for data handling, security measures, and breach management. It should be used when organizations need to formalize their data protection obligations, particularly in controller-processor relationships. The agreement covers crucial aspects such as data security, cross-border transfers, breach notification procedures, and audit rights, serving as the foundational document for all data protection matters between the parties.
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1. Parties: Identification of data controller, data processor, and any other relevant parties
2. Background: Context of the agreement and relationship between parties
3. Definitions: Key terms used throughout the agreement, aligned with PDPA definitions
4. Scope and Purpose: Details of data processing activities covered by the agreement
5. Data Protection Obligations: Core obligations under PDPA including collection, use, disclosure, and protection
6. Security Measures: Technical and organizational measures required to protect data
7. Data Breach Notification: Procedures and timelines for reporting data breaches
8. Cross-border Transfers: Rules and safeguards for international data transfers
9. Term and Termination: Duration and conditions for ending the agreement
1. Sector-Specific Requirements: Additional requirements for regulated industries (banking, healthcare, etc.)
2. Data Protection Impact Assessment: Requirements for conducting DPIAs for high-risk processing activities
3. Subprocessor Management: Rules for engaging and managing subprocessors when third parties will be involved
4. Joint Controller Provisions: Responsibilities and obligations when parties act as joint controllers
1. Schedule 1 - Processing Activities: Detailed description of processing activities, categories of data, purposes
2. Schedule 2 - Security Measures: Technical and organizational security measures specification
3. Schedule 3 - Approved Subprocessors: List of approved subprocessors and their processing activities
4. Schedule 4 - Transfer Mechanisms: Details of cross-border transfer mechanisms and safeguards
5. Appendix A - Data Breach Response Plan: Detailed procedures for handling data breaches
6. Appendix B - Audit Requirements: Audit procedures and requirements
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