Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems

In March 2024, PDPC issued the Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems, spelling out how the PDPA applies in concrete AI scenarios. The guidelines cover three common situations: (1) using personal data to train, test, and monitor AI models — which can rely on the Business Improvement Exception or Research Exception, subject to reasonableness, data minimisation, and de-identification thresholds; (2) using AI for recommendations or decision-making — which triggers notification and consent obligations, and where decision-making applications must inform data subjects; (3) best-practice templates for Data Protection Impact Assessments (DPIA). This is the key document by which PDPC translates the 2020 PDPA amendments (legitimate interests, Business Improvement Exception) into an operational handbook for AI deployment, forming — together with Section 244 of the Copyright Act — Singapore's dual legal foundation on the training side.