CIPP/A: Certified Information Privacy Professional/AsiaDemo

Question

Assuming that the monitoring was lawful, can Singabank disclose Jimmy’s personal data to Bigbank?

A No, because Jimmy is not in the division that Bigbank seeks to acquire.
B No, because the data was collected for the express purpose of complying with Singabank's privacy policies.
C Yes, if Singabank informs Jimmy of the disclosure of his personal data before it occurs.
D Yes, if Jimmy's personal data is necessary for Bigbank to determine whether to proceed with the acquisition.

Explanation

Singapore’s PDPA permits an organisation involved in a prospective business asset transaction to disclose an applicable individual’s personal data without consent only where the data is necessary for the prospective party to determine whether to proceed with that transaction. A proposed acquisition of a banking division is such a transaction; disclosure is therefore permitted only if Jimmy’s data is necessary for Bigbank’s decision.

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Personal Data Protection Act 2012 — First Schedule

CIPP/A: Certified Information Privacy Professional/AsiaDemo

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