Technology & Data Privacy

Personal Data Protection Commissioner Issues Advisory on the Collection, Processing and Storage of Personal Data During the Conditional Movement Control Order

Following the shift from the previous Movement Control Order to the Conditional Movement Control Order (“CMCO”) in Malaysia (which is currently scheduled to end on 9 June 2020), most industries and businesses have been allowed to resume operations, subject to compliance with standard operating procedures issued by the Malaysian Government. On 29 May 2020, the Personal Data Protection Commissioner issued an Advisory on the Procedure for the Handling of Activities relating to the Collection, Processing and Storage of Personal Data by Business Premises during the Conditional Movement Control Order (“Advisory”), which outlines the minimum requirements to be complied with by business premises operating during the CMCO period in order to comply with the seven Personal Data Protection Principles (“PDP Principles”) of the Personal Data Protection Act 2010.

In this Update, we analyse some of the minimum requirements against each of the PDP Principles as identified in the Advisory to be observed by businesses when collecting personal data for contact tracing purposes during the CMCO period.