The European General Data Protection Regulation (GDPR) was the first data privacy law that entered into force in 2018. Since then, it has influenced many privacy laws globally.
In the Asia-Pacific region, countries like Singapore, South Korea, and Japan are emerging as leaders in data protection regulation and innovation. These countries are building agile, business-friendly frameworks that facilitate international data transfers and digital trade while safeguarding individual rights.
Read more about Consent frameworks in Japan (APPI), South Korea (PIPA), and Singapore (PDPA) to know better about Asia-Pacific nuances.
Asia-Pacific Privacy Laws: Consent in Japan (APPI), South Korea (PIPA), and Singapore (PDPA)
One of the challenges for individuals doing business in the Asia Pacific (APAC) region is the emerging data privacy laws and cybersecurity requirements. Data protection is no longer limited to Europe’s GDPR or California’s CCPA. In the Asia-Pacific region, countries like Japan, South Korea, and Singapore have established strong frameworks to regulate how businesses collect, store, and use personal data.
Non-compliance with the privacy laws of Japan, South Korea, and Singapore can lead to significant penalties.
If your organization operates in the APAC region, understanding consent requirements under APPI, PIPA, and PDPA is critical.
Note that even if your business is based outside of these markets but collects or handles data belonging to their citizens, your business must also comply with APPI, PIPA, and PDPA.
This blog article breaks down the essentials of consent frameworks in Japan, South Korea, and Singapore, and other Asia-Pacific nuances.
Japan’s APPI: How Consent Works Under the Act on the Protection of Personal Information
Japan’s Act on the Protection of Personal Information (APPI) is one of the oldest privacy frameworks in Asia, that continues to evolve. The APPI came into effect in 2003, and the amended provisions came into force on April 1, 2022.
Japan’s APPI is the most GDPR-aligned data privacy law in Asia.
Japan’s APPI consent requirements:
- Transparency
Organizations must clearly explain the purpose of data collection and give users the ability to opt in and opt out of data collection. Businesses must implement clear and transparent privacy notices. - Strong individual rights
Individuals have the right to control their Personal Information. Data subjects’ rights include: right to access, right to correct/ add/ delete, right to suspension of use, right to stop provision to third parties, right to be informed about third-party transfers, right to withdraw consent, and right to file complaints. - Consent for sensitive data
Explicit user consent is required to collect or process sensitive information, such as medical, biometric, criminal records, social status, or political data. - Consent for transferring data to a third party
Businesses must obtain explicit, informed opt-in consent and have a contract before sending data to a third party. However, consent for third-party data sharing excludes data sharing with a processor for a designated purpose. - Consent for cross-border transfers
Businesses must obtain explicit, informed opt-in consent from individuals before transferring their personal data internationally to countries lacking adequate data protection. Businesses must inform individuals about the data protection regulations and security measures in the destination country.
EU adequacy status Japan’s APPI has an EU adequacy status, enabling seamless EU–Japan data flow.
Japan’s APPI is regularly updated, reflecting global norms.
CookieScript CMP could help you to comply with Japan’s APPI and other data privacy laws around the globe.
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South Korea’s PIPA: A Closer Look at Consent and User Data Rights
South Korea’s Personal Information Protection Act (PIPA) is one of the strictest data privacy laws in the world. The law is comprehensive and strictly enforced.
PIPA came into effect on September 30, 2011. The main amendments came into force in 2023, that introduced new guidelines for data processing, higher fines for data breaches, and stricter requirements for obtaining user consent. Recently, South Korea is focusing on protecting data in emerging technologies, such as AI and IoT, ensuring personal information safety.
South Korea’s data privacy law places a strong emphasis on explicit user consent.
South Korea’s PIPA consent requirements:
- Transparency
Businesses must disclose the types of personal data collected and processed, the purposes of such processing, the data transfer to third parties, data retention and deletion practices, and other data. - Legal basis for data processing
Businesses need the data subject's consent for data processing. Consent must be obtained before collecting or using personal data. Data controllers must obtain informed and freely givenexplicit consent from individuals. - Granular consent
General consent for processing all personal data is not enough. Specific consent is required for data processing of several classes, including data transfers to third parties, international data transfers, processing of sensitive personal information, use of personal data for marketing purposes, and other cases. - Consent for sensitive data
Businesses must obtain separate, specific consent for sensitive information. - Consent for automated decision-making
PIPA sets strong rules on automated decision-making. - Strong individual rights
South Korea’s PIPA provides individuals the rights to withdraw consent, request data access, correction, or deletion.
To comply with South Korea’s PIPA requirements, businesses should implement granular consent mechanisms, avoid bundled agreements, obtain separate consent for sensitive data and automated decision-making, and keep records of consent.
CookieScript CMP could help you to comply with South Korea’s PIPA and avoid fines for non-compliance.
Singapore’s PDPA: What Businesses Need to Know About Consent Management
Singapore’s Personal Data Protection Act (PDPA) was initially introduced in 2012 and later amended in 2020. The first phase of implementation took effect on February 1, 2021.
Singapore’s PDPA takes a more flexible approach compared to Japan’s and South Korea’s data privacy laws. However, PDPA still aims to safeguard user rights and require user consent.
Singapore’s PDPA consent requirements:
- Transparency
Similarly to other privacy laws, businesses must inform individuals about the types of personal data collected and processed, the purposes of such processing, the data transfer to third parties, data retention and deletion practices, and other data. - Prior consent
Businesses must obtain consent before any data collection, use, or disclosure. - Purpose limitation
Consent is valid only for the specific purpose for which it was collected. Businesses cannot use the data for unrelated purposes without separate consent. - Withdrawal of consent
Individuals have the right to withdraw their consent at any time. Upon withdrawal, businesses must stop processing the data immediately. - Granular consent
General, bundled consent for processing all personal data is not enough. Data processing for different purposes, especially for sensitive data, requires separate consent. - Legitimate interest’s exception
Recent updates to the PDPA introduced the legitimate interest’s exception, which allows businesses to process data without consent if the benefits clearly outweigh the risks to individuals. However, businesses are still required to implement adequate safeguards to protect user data.
Note that penalties for non-compliance with Singapore’s PDPA are severe. The maximum financial penalty for non-compliance could reach up to SGD 1 million. For organizations with a turnover of more than SGD 10 million, the maximum fine could be 10% of the organization’s annual turnover.
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How to Comply with Consent Requirements Across Japan, South Korea, and Singapore?
To comply with Japan’s, South Korea’s, and Singapore’s data privacy laws, businesses should:
- Provide clear and specific privacy notices.
- Obtain granular consent for data processing of several classes.
- Maintain records of consent for audits.
- Respect data subjects’ rights.
- Enable users to easily withdraw consent.
- Monitor cross-border data transfer rules, especially under APPI.
The easiest and most reliable way to achieve compliance across multiple jurisdictions is by using a Consent Management Platform (CMP). A CMP enables businesses to design cookie banners, notify users about the collection of their personal data, and obtain and store user consent for proof of compliance.
CookieScript CMP could be the best choice for your business. It provides essential features and functionalities such as:
- Cookie banner customization
- Cookie policy
- Cookie Scanner
- Consent recordings
- Language support
- Third-party cookie blocking
- Integrations with CMS platforms like WordPress, Shopify, Drupal, Joomla, etc.
- Google Consent Mode v2 integration
- Certification by Google
CookieScript CMP also offers many features that other CMPs are missing, including:
- geo-targeting
geo-targeting is an important feature that ensures that the right consent banner appears based on the user’s location, enabling compliance with many privacy laws. This means that you can have different cookie banners designed for different privacy laws. For example, when a user from Japan visits your website, they are presented with a Cookie Banner, designed to comply with Japan’s APPI. The CookieScript geo-targeting feature is available for 250 countries and 50 US states. - Cookie banner sharing
CookieScript allows you to share your banners with multiple users. It is a requested functionality for web agencies that have many customers. Web agencies can select between read-only vs full-access Cookie Banner sharing, Moreover, it is possible to share a banner with any user, even if the one does not have an account at CookieScript. - Cross-domain cookie consent sharing
CookieScript enables both sub-domain and cross-domain Cookie Consent sharing. Cross-domain consent allows website owners to store Cookie Consent settings from a single user across multiple domains. Website visitors will only see a cookie banner on their first visit to a website and will not see the banner on subsequent visits to that site or other linked sites. - CookieScript API
The CookieScript API allows you to customize the behavior of cookie banners, manage Cookie Consent and scans, retrieve and update cookie declarations, and control individual cookies automatically.
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Frequently Asked Questions
What are the key privacy laws in the Asia-Pacific region?
The major data protection laws in APAC include Japan’s APPI (Act on the Protection of Personal Information), South Korea’s PIPA (Personal Information Protection Act), and Singapore’s PDPA (Personal Data Protection Act). Each law sets specific rules for transparency, user consent, sensitive data safeguard, data subjects’ rights, and cross-border transfers. CookieScript CMP can help you to comply with APAC privacy laws.
How does consent under Japan’s APPI work?
Under APPI, organizations must obtain user consent to collect or use sensitive personal data and before transferring personal data overseas. Consent must be explicit, informed, and voluntary, and businesses must clearly explain the purpose of data collection. Use CookieScript CMP to inform users about data collection and obtain user consent in accordance with Japan’s APPI.
Why is South Korea’s PIPA considered one of the strictest privacy laws?
South Korea’s PIPA requires explicit, prior consent for almost all data processing activities. Separate consent is needed for sensitive data and automated decision-making. Individuals have strong rights to access, correct, delete their data, and withdraw consent. Due to these requirements, businesses must implement granular consent for the data processing of several classes, including data transfers to third parties, international data transfers, the processing of sensitive personal information, and the use of personal data for marketing purposes.
What are Singapore’s PDPA consent requirements?
The PDPA follows a consent-first approach, where organizations must notify individuals about the purpose of data collection and obtain their consent. Data processing for different purposes, especially for sensitive data, requires separate consent. However, PDPA also allows processing without consent in limited cases, such as legitimate interests, contractual necessity, and legal compliance. Individuals also have the right to withdraw consent at any time. Use CookieScript CMP to obtain user consent.
How do Asia Pacific privacy laws differ from GDPR?
Asia-Pacific laws like South Korea’s PIPA, Japan’s APPI, and Singapore’s PDPA aim to balance commercial pragmatism with data subjects’ privacy protections. Laws emphasize risk-based governance over strict consent models, allowing for greater regulatory flexibility and focusing on cross-border data transfer. CookieScript CMP can help you to comply with Asia Pacific privacy laws.
What should businesses do to comply with APAC consent rules?
Businesses should provide clear and specific privacy notices, obtain granular consent for the processing of multiple classes of data, maintain records of consent for audits, enable users to easily withdraw consent, and monitor cross-border data transfer rules, especially under APPI. The easiest way to comply with APAC consent rules is to use a Consent Management Platform (CMP) like CookieScript.