Introduction: Good Intentions, Weak Execution
Most small and mid-sized businesses in Singapore want to comply with the Personal Data Protection Act (PDPA) — but many struggle with the how.
Policies may exist, but staff aren’t sure what they mean in practice. Forms are saved somewhere, but no one knows which version is current.
The result? Gaps that can quietly grow into risks — both for compliance and customer trust.
After working with dozens of SMEs, here are the five most common PDPA gaps we see — and practical ways to close them.
1. No Central Data Inventory
Many SMEs don’t have a clear picture of what personal data they hold, where it’s stored, or who can access it.
Without this, it’s almost impossible to respond properly to access, correction, or deletion requests.
Fix it:
Start small. Create a simple data inventory table with columns for:
- Type of data (e.g., customer, staff, vendor)
- Location (email, HR system, Google Drive, etc.)
- Access owner
- Retention period
Once this is in place, you can easily identify what’s redundant and what needs protection.
2. Policies Without Processes
Many businesses copy-paste PDPA policies from the internet but never translate them into daily practice.
Employees know there is a policy, but not what to do if a customer asks to withdraw consent or report a breach.
Fix it:
Pair every policy with a simple procedure or flowchart.
For example, “Access Request Handling” should clearly show:
- Who receives the request
- How to verify the requester’s identity
- What records to update
- What deadlines apply
Policies tell staff why something matters; procedures tell them how to do it.
3. Weak Vendor Oversight
SMEs often share data with payroll firms, IT vendors, or marketing agencies — but don’t check how those vendors handle it.
If a third party mishandles your customers’ data, your organisation still bears responsibility.
Fix it:
Add data protection clauses into all vendor agreements, requiring:
- Confidential handling of personal data
- Notification of any breach within 24 hours
- Return or destruction of data when the contract ends
For existing vendors, send a short questionnaire to confirm how they manage PDPA obligations.
4. Training Once (and Never Again)
Staff may have attended a briefing when the PDPA first came out — but years later, the rules, people, and risks have all changed.
Most incidents happen because someone simply didn’t know better.
Fix it:
Run short annual refreshers.
Focus on real-life scenarios: mis-sent emails, lost thumb drives, or phishing links.
Use attendance sheets or LMS records as evidence for audits — these count as artefacts for DPTM or Cyber Trust Mark certification too.
5. No Breach Playbook
Even companies with solid policies can freeze during a breach. Who informs PDPC? Who drafts the client email? What should IT isolate first?
Fix it:
Create a 24-hour playbook that answers:
- Who to call first (DPO / IT lead / management)
- How to contain the issue
- How to record evidence
- When to notify PDPC or affected individuals
Rehearse this once a year using a simple tabletop drill — it builds confidence and shortens reaction time dramatically.
Final Thoughts
PDPA compliance isn’t just about avoiding fines — it’s about showing customers that you handle their data with care.
Start by fixing these five basics, and you’ll already be ahead of most of the market.
When you’re ready, the next step is formalising your framework through DPTM certification or the Cyber Trust Mark — both of which build real business credibility.
Next Step
Download our PDPA Readiness Self-Assessment Guide and see where your organisation stands today.
Or contact us to learn how Apex helps Singapore businesses close PDPA gaps quickly and confidently.