Generally, organisations may continue to use the personal data collected prior to the effective date of the data protection rules, unless you withdraw your consent (if consent had previously been given) or indicate that you do not consent to such use of the personal data. Consent will need to be obtained if the existing data is to be used for a new purpose different from the purpose for which it was collected, or if the existing data is to be disclosed to another organisation or individual, unless any exception applies. These exceptions are set out in the Second, Third and Fourth Schedules of the PDPA respectively. This includes exceptions catering to certain emergency situations, investigations, publicly available data or where the personal data is used for evaluative purposes.For example, if a company has been using your personal data to provide after-sales customer support prior to the PDPA, it can continue to do so after the PDPA comes into effect, even if it did not obtain consent previously. However, if it now intends to use the same personal data for direct marketing where it had not collected the personal data for this purpose, consent will need to be obtained for such a purpose. If the organisation wishes to use the personal data for telemarketing, it will separately have to ensure compliance with the DNC provisions under the PDPA. Generally, organisations may continue to use the personal data that was collected prior to the effective date of the data protection rules, for the reasonable purposes for which the personal data was collected.
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