Data Controller Agreement Template for Singapore

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Key Requirements PROMPT example:

Data Controller Agreement

"Need a Data Controller Agreement for our Singapore-based fintech company sharing customer payment data with a third-party analytics provider, with specific emphasis on cross-border data transfers to their EU servers and breach notification procedures."

Document background

This Data Controller Agreement is essential when two or more organizations jointly determine the purposes and means of processing personal data in Singapore. The agreement, governed by Singapore's PDPA 2012, establishes clear responsibilities, compliance obligations, and liability allocation between joint controllers. It addresses key requirements including data protection measures, breach notification procedures, data subject rights management, and cross-border transfer protocols. This document is particularly crucial for organizations sharing data processing responsibilities while maintaining independent control over certain aspects of data processing.

Suggested Sections

1. Parties: Identification of the Data Controller and other contracting parties, including registration details and addresses

2. Background: Context of the agreement and relationship between parties

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

4. Scope and Purpose: Define the scope of data processing activities and legitimate purposes

5. Data Protection Obligations: Core obligations under PDPA including collection, use, disclosure, and protection of personal data

6. Security Measures: Technical and organizational measures for data protection

7. Breach Notification: Procedures for handling and reporting data breaches

8. Data Subject Rights: Procedures for handling data subject requests and rights

Optional Sections

1. Cross-border Transfers: Requirements and compliance measures for international data transfers outside Singapore

2. Sector-Specific Requirements: Additional requirements for regulated industries such as healthcare, finance, or telecommunications

3. Sub-processing: Terms and conditions for engaging and managing third-party data processors

4. Data Protection Impact Assessment: Requirements and procedures for conducting DPIAs for high-risk processing activities

Suggested Schedules

1. Schedule 1 - Categories of Personal Data: Detailed list of personal data types being processed under this agreement

2. Schedule 2 - Technical and Organizational Measures: Comprehensive description of security measures and controls implemented

3. Schedule 3 - Sub-processors: List of approved sub-processors, their roles, and responsibilities

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

5. Schedule 5 - Contact Points: Key contacts for data protection matters and breach notifications

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co

Relevant legal definitions

Clauses

Relevant Industries

Financial Services
Healthcare
Technology
E-commerce
Education

Relevant Teams

Legal
Information Security
Compliance
Data Protection
Information Technology

Relevant Roles

Chief Privacy Officer
Data Protection Officer
Chief Information Security Officer
Compliance Manager
Privacy Counsel

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Authors

Alex Denne

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