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

July 26, 2013

Legal Issues in Technology Outsourcing Arrangements

Bangkok Post, Corporate Counsellor Column

Technology outsourcing arrangements are becoming more and more widespread. Commercially, they can allow businesses to save money while at the same time improving the quality of IT services.

But these arrangements also raise a number of legal issues for both vendors and customers. Depending on the specifics of the outsourcing, the contracts may involve agreements for consulting, software development, licensing, implementation, and maintenance, among others. The following are some of the issues that may be of concern when negotiating technology outsourcing agreements.

When the outsourcing involves a licensing component, attention must be paid to precisely what is being licensed and the rights and obligations of the licensor and licensee. For example, regarding a software license, the customer should consider whether the terms of the license are sufficient to allow him actually to use the licensed software for the intended purpose.

If the customer will need to make improvements or other modifications to the licensed software, he should ensure the license terms allow for that. On the other side, the vendor will want to make certain the agreement includes provisions that sufficiently protect the intellectual property being licensed.

In situations where the vendor is to provide maintenance or other support, service-level agreements are important. Among other standards, these stipulate the times within which the vendor is contractually obligated to respond to requests to fix bugs or deal with other problems that may arise. Often, the specified response time frames differ, depending on the severity of each problem.

Service-level agreements are helpful to both parties in that they function to achieve a mutual understanding on response times and what actions the vendor will take when problems are reported. The agreement may also specify liquidated damages to be payable when the vendor is late or otherwise fails to meet these obligations.

Another issue involves modifications and enhancements a customer may request that go beyond the scope originally agreed. While there are a number of commercial arrangements that can deal with these, it is generally important to agree, from the beginning, that such modifications and enhancements shall be made only pursuant to a written change order signed by both parties.

The change order should clearly describe the scope of the modification or enhancement to be made and should clearly set out the price to be paid for the change. This helps to ensure both parties have a common understanding regarding deliverables and costs.

When contracting with a vendor’s local subsidiary, some customers are concerned about the ability of the subsidiary to fulfill its contractual obligations. Some of these concerns can be addressed by a letter of guarantee from the parent company of the local subsidiary.

The wording typically provides that the parent company will perform, or cause to be performed, the obligations of the local subsidiary in the event the local subsidiary fails to do so.

Following a failure to perform, the customer will give notice to the local subsidiary to perform, and if the local subsidiary still fails to perform, the customer will then make a demand on the parent company, under the letter of guarantee.

In some outsourcing arrangements, there are major barriers to switching vendors. When significant development and customization is required to put a new system in place or significant time or expense is otherwise involved in switching to a new vendor, the incumbent vendor is in a good position to demand price increases in future years.

For this reason, it is important to agree in advance how pricing adjustments in future years will be handled. Some contracts are written to include a numeric percentage increase to be applied on a particular schedule—perhaps at the beginning of each calendar year or the start of every three contract years, for example. Others are written to be adjusted in alignment with a particular consumer price index.

On a related issue, careful consideration should be given to termination clauses. While the parties may easily agree that either party should have the right to terminate the agreement following a party’s failure to cure a material breach, there may be concerns about a party’s ability to terminate for convenience.

Whether it is appropriate to allow termination for convenience depends largely on the nature of what is being outsourced. In mission-critical installations, presumably the customer will not want the vendor to be able to terminate so easily. On the other hand, the customer will likely want some ability to terminate for reasons other than breach—for example, in the event of selection of a replacement vendor.

A related issue is the amount of notice to be required in the event of termination. At the very least, the agreement should be written to provide notice that gives sufficient time to arrange for a new vendor to put in place a replacement system.

Thought should also be given to what will happen if the vendor goes out of business or otherwise stops supporting the technology. In installations that are critical to the customer’s ability to operate, a lack of support could be quite problematic. For this reason, many customers opt for source code escrow agreements. In arranging these, particular attention should be given to the terms of release and the identity of the selected escrow agent.

These are but a few of the important issues that may need to be addressed in contracts that provide for technology outsourcing. Of course, the specific issues of concern will vary, depending on the nature of what is being outsourced. For this reason, both customers and vendors should take the necessary steps to ensure they have a full understanding of the legal issues and their options for structuring the transaction.

RELATED INSIGHTS​ 

August 25, 2026
Vietnam has enacted a new decree establishing administrative penalties for violations in the fields of cybersecurity and personal data protection. Decree No. 330/2026/NĐ-CP (Decree 330), issued and effective from August 19, 2026, provides a detailed sanctions framework for noncompliance with the Law on Personal Data Protection (including its implementing regulations under Decree 356/2025/ND-CP) and the Law on Cybersecurity, together with their guiding decrees. The issuance of Decree 330 signals that the practical grace period previously perceived by many businesses may be drawing to a close, with active regulatory enforcement in these areas expected to commence in earnest. Scope and Key Provisions Decree 330 has extraterritorial effect and applies to both onshore and offshore companies. For offshore companies, it applies to those that (1) provide telecommunications, internet, online-content, information-technology, cybersecurity, or cross-border services and (2) are involved in or related to the processing of personal data of Vietnamese citizens and certain other people of Vietnamese origin. Decree 330’s key provisions cover the following areas: Administrative penalties for violations relating to the protection of national security and public order in cyberspace, including the dissemination of unlawful, false, or unverified information. Sanctions for cyberattacks, unauthorized access, introduction of harmful code or programs, and failure to cooperate with specialized cybersecurity forces. Sanctions for personal data protection violations, such as consent, cross-border data transfers, impact assessments, breach notification, and data-subject rights, among others—with maximum fines of up to 5% of an organization’s preceding-year revenue for cross-border transfer violations, or up to VND 3 billion for other data-protection breaches. Personal Data Protection Penalties The key sanctions for personal data protection violations are as follows: Consent violations: Fines of up to VND 70 million (approx. USD 2,642), plus potential additional sanctions and remedial measures including irreversible deletion of personal data collected without consent and confiscation of
August 25, 2026
Thailand’s Electronic Transactions Development Agency (ETDA) is studying potential new regulatory measures for digital platform services that could significantly expand the country’s digital platform governance framework. The ETDA has already conducted one public consultation session on the proposed measures and will hold additional sessions on August 25 and September 2, 2026, covering five types of platform services under the Royal Decree on Digital Platform Services B.E. 2565 (2022). The measures under study are preliminary and may be changed based on consultation outcomes. Foundational Measures Applicable to All Platform Types Seven baseline obligations would apply across all digital platform categories: Transparency reports. Platforms must prepare and publish statistical reports on platform governance activities, including the number of content items removed or restricted and appeal outcomes, in a comparable format. Notice and action mechanism. Platforms must establish minimum standards for channels to report potentially illegal content or goods, conduct case-by-case review, provide explanations when content is removed or restricted, and maintain an internal appeals channel. Rights over automated decision-making. Users significantly affected by automated decisions are granted rights to request an explanation, request human review, and contest the decision. Service level agreements (SLAs). Platforms must publish minimum standards for response times, processing timelines, progress notifications, and remedies for incidents on the platform. Labeling of AI-generated content. Content generated or modified by AI must carry visible labels and machine-readable metadata, with exceptions for creative works that disclose AI use in a nonmisleading manner. Prohibition of dark patterns. User interface designs that deceive, coerce, or distort user decision-making are prohibited, including hiding critical information, creating false urgency, or making service cancellation unreasonably difficult. Business user fairness. Platforms must meet minimum standards for the treatment of sellers, workers, and content creators, including advance notice of term changes, explanation of account suspensions or visibility reductions,
August 20, 2026
Thailand has established a new cross-ministerial committee to oversee data center operations nationwide. On August 5, 2026, the Thai cabinet approved the Prime Minister’s Office Regulation on the Data Center Business Policy Committee, which was published in the Government Gazette on August 13, 2026, and is now in effect. The regulation reflects the government’s policy to elevate Thailand’s digital economy and promote investment in digital infrastructure and AI. The key features of the new committee are outlined below. Definition of “Data Center” Under the regulation, “data center” is defined as a building, premises, or structure that uses electronic equipment to provide services related to the collection, storage, processing, hosting, or transmission of data by electronic means to third parties that are not affiliates, as further determined by the Data Center Business Policy Committee. Committee Composition The committee will be chaired by a deputy prime minister designated by the prime minister, and will have three vice-chairs comprising the ministers of digital economy and society, interior, and energy. The committee also includes 12 ex-officio members: the permanent secretaries of finance, agriculture, natural resources, energy, interior, digital economy, industry, and commerce; the secretaries-general of the Board of Investment (BOI), Energy Regulatory Commission, National Broadcasting and Telecommunications Commission (NBTC), and National Water Resources Office; and the director of the Energy Policy and Planning Office. Up to three expert members may be appointed by the prime minister for two-year terms, renewable once. The secretary-general of the National Economic and Social Development Council (NESDC) serves as member and secretary, with up to two NESDC officials serving as assistant secretaries. Powers and Duties The committee is empowered to: Propose policies, standards, and operational frameworks for government agencies in approving, licensing, issuing investment promotion certificates, or providing services to data center operators in Thailand; Study, analyze, and
August 14, 2026
Thailand’s Office of the Insurance Commission (OIC) has issued guidelines clarifying the boundaries between permissible and prohibited activities for unlicensed individuals—including influencers, bloggers, and content creators—when communicating about insurance products on social media. The Good Practice Guidelines for Persons Not Licensed as Insurance Agents or Brokers Regarding the Dissemination of Insurance Content Through Digital Media B.E. 2569 (2026) took effect on July 24, 2026. Activities Requiring a License The guidelines reserve the following activities for licensed agents and brokers: Soliciting or facilitating insurance contracts. Providing personalized advice on product suitability. Recommending policy cancellation to purchase promoted products. Creating links that facilitate contract formation. Receiving performance-based compensation tied to policies or premiums generated. Importantly, boilerplate disclaimers such as “this is not a recommendation to buy insurance” will not shield individuals from liability if the OIC views the content as personalized advice or solicitation. Permitted Activities Unlicensed persons may present general educational content about insurance—such as explaining terminology, sharing industry statistics, reporting news, or sharing personal experiences—provided the content does not target specific individuals to purchase from specific companies. The guidelines also set out best practices for communication, including presenting information in a fair and balanced manner that covers both benefits and limitations, encouraging consumers to read policy terms and consult licensed professionals, verifying information from credible sources before dissemination, and exercising special care when the audience may include vulnerable groups such as persons aged 60 and older. Prohibited Practices Prohibited practices include fear-based marketing, creating artificial urgency, omitting material limitations, making exaggerated claims, falsely claiming professional credentials, using fake engagement mechanisms, and sharing false or misleading content. The guidelines also reinforce the prohibitions under section 83 of the Life Insurance Act B.E. 2535 and section 78 of the Non-Life Insurance Act B.E. 2535 against soliciting insurance contracts with foreign operators