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Controller To Controller DPA

Controller To Controller DPA Template for Singapore

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Key Requirements PROMPT example:

Controller To Controller DPA

"I need a Controller To Controller DPA under Singapore law for sharing customer data between our fintech company and a partnering bank, with specific provisions for cross-border transfers to Australia starting March 2025."

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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) @ Ƶ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
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Industries

Personal Data Protection Act 2012 (PDPA): Singapore's primary data protection legislation that includes the Nine Data Protection Obligations and mandatory breach notification requirements

Personal Data Protection Regulations 2021: Secondary legislation under PDPA providing detailed requirements for data protection compliance

Personal Data Protection (Notification of Data Breaches) Regulations 2021: Specific regulations detailing the requirements and procedures for mandatory data breach notifications

PDPC Advisory Guidelines on Key Concepts: Official guidelines from the Personal Data Protection Commission explaining key concepts and interpretation of the PDPA

PDPC Advisory Guidelines on Transfer of Personal Data Outside Singapore: Specific guidelines governing international data transfers and cross-border data protection requirements

ASEAN Framework on Personal Data Protection: Regional framework providing principles for data protection in ASEAN member states

APEC Privacy Framework: Asia-Pacific Economic Cooperation framework for privacy and data protection standards

Cybersecurity Act 2018: Singapore legislation establishing a framework for the protection of critical information infrastructure and cybersecurity

Electronic Transactions Act: Singapore law governing electronic transactions and digital signatures, relevant for data processing agreements

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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