9/18/2019 Singapore | Global Network Initiative the IMDA has the power to revoke telecommunications licences in serious cases of breach. Any Telco Operator aggrieved by any decision or direction of the IMDA (either under the TA or in a Code of Practice) may within 14 days of the receipt of the decision or direction request that the IMDA reconsider the matter or appeal to the Minister. These powers of appeal are derived from section 69 of the TA. The reconsideration request power cannot be exercised to both the IMDA and the Minister; only one can be consulted. If both are consulted at the same time, the appeal is withdrawn. The IMDA has the power to confirm, vary or reverse any decision or direction. If the Telco Operator is aggrieved by the decision of the IMDA, the Telco Operator can further appeal SINGAPORE 3 2017 to the Minister within 14 days of the receipt of that decision. Alternatively an appeal can be filed directly with the Minister. If an appeal is filed with a Minister, there is no recourse to the IMDA. In either case, such an appeal must state as concisely as possible the circumstances for the appeal, the issues and ground for this appeal and submit all relevant facts, evidence and arguments for the appeal. If these requirements are not complied with, the appeal can be rejected. The Minister’s decision is final under the TA, and until there is a final decision, the decision or direction that is being appealed must be complied with. Therefore, in practice, any interception or control, stopping, delaying or censoring would need to be complied with until the final decision of the Minister, who in turn may have given the direction that is being appealed. An aggrieved party who has unsuccessfully appealed to the Minister does have one final challenge by initiating a judicial review in the courts. THE PERSONAL DATA PROTECTION ACT (a) COLLECTION, USE AND DISCLOSURE OF DATA The Personal Data Protection Act (“PDPA”) sets out various restrictions surrounding the collection, use, disclosure and care of personal data. Personal data is defined in the PDPA as data, whether true or not, about an individual who can be identified a) from that data; or b) from that data and other information to which the organisation has or is likely to have access. The PDPA is regulated by the Personal Data Protection Commission (“PDPC”). https://clfr.globalnetworkinitiative.org/country/singapore/ 5/13