ObligationConsultationConsultation

Access and Correction Obligations Apply Despite GenAI Technical Challenges

Is this legally binding?

Consultation. Proposed, not final. Read it, plan for it, and do not treat it as settled.

Proposed and not final. Nothing here can be enforced against you yet.

GUIDANCE interpreting binding ss 21-22: massive training datasets, embeddings and context windows do not relieve organisations of access/correction duties. Best practices: upstream accuracy checks, data cleaning, provenance records, case-by-case review, removing data from training sets, output filters, and tracking machine unlearning.

From the source
“Notwithstanding the above, organisations are expected to adopt the following best practices to support compliance with their Access and Correction Obligations where reasonable”
paras 10.1-10.4 (refined in final)

pdpc.gov.sg Show it on the map

What this connects to

3 relations. Official relations are the ones the source documents state; anything marked GAGE analysis is our reading, not an agency's.

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ObligationAccess Obligation (s 21)Binding
Guideline interprets binding PDPA provision; guideline itself is not legally binding
ObligationCorrection Obligation (s 22)Binding
Guideline interprets binding PDPA provision; guideline itself is not legally binding

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SectionPost-Deployment, Addressing Individuals' Requests About Personal DataGuidance
Structural decomposition of the source instrument

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