What should organisations and individuals take note of in complying with withdrawal of consent requirements?
are a number of requirements that both individuals and organisations need to
take note of. Some of these are:
· The individual must
give reasonable notice of the withdrawal to the organisation. As a general rule of
thumb, ten business days is considered to be reasonable notice.
· On receipt of the
notice, the organisation must inform the individual of the likely consequences
of withdrawing consent. Consequences for withdrawal of consent could simply be
that the organisation would cease to collect, use or disclose the individual’s
personal data for the purpose specified by the individuals. However, if there
are other likely consequences, the organisation must also inform the individual
· An organisation must
not prohibit an individual from withdrawing consent, although this does not
affect any legal consequences arising from such withdrawal.
· Upon withdrawal of
consent, the organisation must cease (and cause its data intermediaries and agents
to cease) collecting, using or disclosing the personal data, as the case may
be, unless the collection, use or disclosure of the personal data without
consent is required or authorised under the PDPA or any other written law.
may provide in their marketing messages a facility for individuals to withdraw
their consent (e.g. by clicking on an “unsubscribe” link within an e-mail).
Organisations are encouraged to clearly indicate the scope of the withdrawal in
such instances. Organisations are also encouraged to inform individuals of how
they may withdraw consent for matters outside the scope of such withdrawal.
some cases, individuals may provide organisations a general withdrawal notice
for marketing, i.e. it is not clear as to the channel of receiving marketing
messages for which consent is withdrawn. In such cases, the PDPC would consider
that any withdrawal of consent for marketing sent via a particular channel will
be considered to only apply to all messages relating to the withdrawal sent via
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