An insurer wishes to transfer policyholder data to a cloud server located overseas. Under the Transfer Limitation Obligation, this is permitted only if:
The Transfer Limitation Obligation permits overseas transfer only where the organisation ensures the transferred data receives a standard of protection comparable to that under the PDPA (e.g. via contractual clauses or binding corporate rules).
Membership of ASEAN or the age of the data is irrelevant; what matters is comparable protection.
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