You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

January 30, 2026

Key Takeaways from Thailand’s Data Privacy Day 2026

Subscribe to Updates

Thailand’s Data Privacy Day 2026, hosted by the Office of the Personal Data Protection Committee (PDPC), underscored the country’s commitment to strengthening personal data protection, advancing regulatory maturity, and preparing organizations for the next phase of PDPA enforcement. The event marked a clear shift from policy-level compliance toward “Privacy in Action,” signaling that operational readiness and real-world implementation are now priorities.

The Office of the PDPC also emphasized that data protection is now a national economic enabler that supports digital trust, competitiveness, and sustainable growth, not just a compliance obligation.

The following insights summarize the key takeaways from the Data Privacy Day 2026 event.

PDPA in Real Life: What Happens to Your Data Today

The Office of the PDPC provided concrete data on enforcement trends and real-world compliance issues facing organizations across Thailand.

Complaints and trends. The Office of the PDPC’s Personal Data Protection Act (PDPA) Center recorded 2,672 PDPA-related complaints as of January 2026, with the highest volumes involving failure to comply with the data minimization principle, collection without lawful basis, and use and disclosure without lawful basis.

Administrative penalties. Several administrative penalties have been imposed on data controllers and data processors across various sectors, including government, healthcare, retail, SMEs and e-commerce, ranging from tens of thousands to several million baht. Most violations stemmed from weak security measures, failure to notify data breaches within the required timeline, absence of a data protection officer (DPO) when required, and noncompliance with governance requirements such as the Record of Processing Activities (ROPA) and data processing agreements with data processors.

Case studies. The Office of the PDPC highlighted specific examples of violations:

  • Hospitals misused personal data for purposes beyond their intended scope (e.g., using personal data collected for providing medical services to send birthday cards)
  • Vendors compromised systems due to inadequate password protocols and the absence of firewalls, resulting in unauthorized access

AI and Privacy: Regulatory Expectations in the Emerging Landscape

Thailand is moving toward a clearer regulatory framework for AI, with the AI Act currently in draft form. While the PDPA does not regulate AI itself, it governs personal data used within AI systems, meaning organizations, not the AI, remain fully accountable for any misuse or unlawful processing of personal data.

Key expectations highlighted for businesses include:

  • The use of AI is allowed, but accountability remains fundamental. Organizations must take full responsibility for how personal data is processed through AI systems.
  • Strong resource and access governance is necessary. Organizations must prevent uncontrolled AI usage and avoid over-sharing of data through proper data classification to restrict AI access to relevant datasets.
  • AI deployment may trigger obligations under other laws. While there is currently no specific law regulating the use of AI, AI deployment may trigger obligations under civil and commercial law, road traffic laws in relation to autonomous systems, and other regulations, reinforcing the need for comprehensive risk assessment.
  • Alignment with forthcoming guidelines. The Office of the PDPC is currently developing practical guidelines on personal data protection in the use and development of AI technologies. Organizations should align AI use with these forthcoming guidelines aimed at supporting safe innovation while adhering to PDPA requirements.

International Cooperation and Cross-Border Transfers

Efforts continue to advance Thailand’s participation in the Global Cross-Border Privacy Rules (CBPR) and strengthen alignment with regional data-protection frameworks. Organizations operating across borders should expect tighter scrutiny of cross-border transfers, including more rigorous requirements for risk assessments and transfer impact analyses to ensure compliance in multi-jurisdictional environments.

Data Breach Incident Monitoring

The PDPC Eagle Eye, a division within the Office of the PDPC, has launched advanced tools such as the PDPC Eagle Eye Crawler, which enables continuous URL access and facilitates 24-hour monitoring of data breach incidents. Additionally, the PDPC Eagle Eye shared details about their plan to send inspection letters to organizations for advisory reasons.

Privacy Maturity Model and Privacy Index

The Office of the PDPC introduced new tools to help organizations assess and improve their data protection practices.

The Privacy Maturity Model assesses an organization’s readiness for personal data protection. The Privacy Index measures data protection levels using both privacy data (such as survey results and Privacy Maturity Model scores) and secondary data (like public information), giving organizations an overview of their privacy risk management capabilities.

Information derived from the Privacy Maturity Model and Privacy Index can then be used toward obtaining the Personal Data Protection Certification Mark, an upcoming certification program to recognize compliant organizations.

Outlook for 2026

Based on the Office of the PDPC’s roadmap and expert discussions during the Data Privacy Day event, organizations should expect several key developments in the coming year:

  • Data privacy must go beyond policy and legal compliance to practical implementation in all systems and operations.
  • Heightened enforcement, driven by expanded automated surveillance capabilities such as the PDPC Eagle Eye Crawler and the rollout of inspection letters for advisory purposes.
  • Stronger national PDPA infrastructure, with continued development of PDPA Centers and Trustmark certification.
  • Closer alignment with international privacy standards, supporting Thailand’s role in cross-border digital trade and strengthened mechanisms to support trusted cross-border data flows.
  • Increased regulatory attention on AI governance, with forthcoming guidance to ensure AI use complies with data-protection principles and standards.
  • A nationwide push toward a “new data-ethics culture” emphasizing legal compliance, incident prevention, organizational cooperation, and the use of technology to strengthen national and public trust, anchored in the national goal of improving data security, attracting investments, and enhancing quality of life.

Organizations should treat 2026 as a critical year for operationalizing privacy compliance, building robust governance frameworks, and preparing for more active regulatory oversight. The shift from policy to practice means that demonstrable implementation, not just documentation, will be the standard by which compliance is measured.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

August 1, 2025
On July 30, 2025, Myanmar’s Cybersecurity Law No. 1/2025 came into effect with the State Administration Council’s issuance of Notification 113/2025. The law, which was enacted on January 1, 2025, aims to regulate various aspects of digital security and online activities. Below are some key provisions, implications, and penalties under the Cybersecurity Law. Extraterritorial penalties. The law contains an important provision that authorizes penalties against Myanmar citizens who are found guilty of violations, even if these occur outside the country’s borders. VPN definition and regulation. Virtual private networks (VPNs) are defined by this law as specific systems that function as backup networks by using technological means in order to ensure the safety of linking networks to each other. This definition sets the framework for subsequent regulations and penalties associated with VPN usage. The law does not restrict individuals or entities from using VPNs; it regulates VPN service providers. Penalties for unapproved VPN services. Establishing a VPN or providing VPN services without approval from the designated ministry (to be appointed later by the government) can result in significant penalties. For individuals, the punishment may be imprisonment for 1–6 months, a fine of MMK 1–10 million (approx. USD 476–4,760), or both, with the proceeds of the violation being confiscated. If the violator is a company or organization, the minimum fine will be MMK 10 million, and the proceeds will be confiscated. Government oversight. The ministry designated by the government is authorized to investigate and take control of cybersecurity services and digital platform services for national defense and security purposes, or upon request from a government department or organization in accordance with respective laws. Licensing requirements. The Cybersecurity Law introduces two types of licenses, valid for a period of 3–10 years, for (1) cybersecurity services and (2) digital platform providers. Digital platforms with
Read More
August 1, 2025
On July 21, 2025, Thailand’s National Cyber Security Agency (NCSA) released a draft amendment to the Cybersecurity Act B.E. 2562 (2019) for public hearing, aiming to address the rapid evolution of technology and increasing complexity of cyber threats. The proposed changes to the country’s cybersecurity framework would extend regulatory oversight to cloud service providers and data center operators hosting data for critical information infrastructure (CII) organizations regulated under the Cybersecurity Act. The NCSA will accept comments on the draft until August 5, 2025. Following the close of the public consultation period, the draft amendment will be subject to further revision during the legislative process. Key proposed amendments are discussed below. Expanded Critical Infrastructure Scope The Cybersecurity Act currently applies only to state agencies, supervising or regulating organizations, and designated CII organizations as announced by the National Cyber Security Committee (NCSC). It defines CII organizations as public or private organizations related to or providing national security, significant public services, banking and finance, information technologies, telecommunications, transportation and logistics, energy and public utilities, or public health. The draft amendment expands the scope of CII organizations to include public and private organizations related to or providing industrial work (to be further defined in subregulations) as well as service providers that store or possess data for CII organizations, such as cloud and data center service providers. CII organizations must comply with cyber threat reporting requirements and are subject to the NCSA’s interception powers. Updated Definitions and New Terminology The draft amendment more clearly distinguishes between “cyber threats” (which have yet to occur but have the potential of causing damage or impact) and “cyber incidents” (which have already occurred and have caused or are expected to cause damage or impact). The draft amendment also expands the definition of “cybersecurity” to explicitly cover both prevention
Read More
July 30, 2025
Artificial intelligence (AI) model training and data scraping are essential processes in the development of modern AI systems. AI model training involves using large datasets to teach machine learning algorithms to recognize patterns, make predictions, or generate new content. Data scraping refers to the automated extraction of information from websites or digital sources, often to assemble the vast datasets required for effective AI training. As these practices become more widespread, questions about the legality of using third-party content—especially copyrighted works—have become increasingly important. In Thailand, the legal landscape for AI developers is shaped primarily by the Copyright Act, which presents unique challenges due to the absence of a fair-use exception. This article examines the copyright-related risks and legal uncertainties facing AI developers under Thailand’s current copyright law and practices, offering strategic guidance for navigating this complex environment. Copyright Risks in AI Scraping and Training Thailand’s Copyright Act does not provide a broad fair use or fair dealing exception, unlike some other jurisdictions, such as the United States. This absence has significant consequences for AI developers: No general defense for AI training: Any use of copyrighted material for AI model training is presumed to be infringing unless a specific, narrow statutory exception applies or explicit permission is obtained from the rights holder. There is no general legal basis for using copyrighted works in AI training without authorization. Increased rights clearance burden: Developers must identify and secure licenses for every copyrighted work included in their training datasets. Given the scale and diversity of data required for effective AI models, this process can be both impractical and costly. Legal ambiguity and litigation risk: The lack of clear statutory guidance or case law leaves developers in a legal gray area. There is no established precedent clarifying whether certain uses of copyrighted material for
Read More
July 24, 2025
Thai authorities have escalated efforts to block unlawful cross-border digital asset business operators. On June 19, 2025, the Ministry of Digital Economy and Society (MDES) issued a notification empowering it to ban internet access to operations or services offered by digital asset business operators who lack licenses from the Thailand Securities and Exchange Commission (SEC) under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). This ban, issued under the 2023 Royal Decree on Measures for the Prevention and Suppression of Technology Crime, particularly aims to block Thai users’ access to services offered by unlicensed offshore digital asset providers via their own apps or websites or through public social media platforms. Compliance Requirements The notification requires internet service providers and social media platforms selected by MDES to immediately impose internet access restrictions on identified apps, websites, and IP addresses of illegal operators upon receiving MDES orders. Takedown Orders There are two tracks for competent officials at MDES to issue orders to operators: If the competent official is notified by the SEC of licensing noncompliance by a particular digital asset business operator, the competent official can issue a takedown order to the operator upon approval from the permanent secretary of MDES. If the competent official independently discovers, or receives a complaint from any third party other than the SEC, that a digital asset business operator may have violated licensing requirements, the competent official can ask the SEC to verify and confirm the relevant facts and noncompliance before seeking approval from the permanent secretary of MDES to issue the takedown order. Streamlined Enforcement Prior to this notification, the SEC could obtain takedown orders only from Thai courts under the 2007 Computer Crime Act to take down or block access to unlicensed digital asset platforms and apps. This was a relatively
Read More