Now halfway through 2025, Thailand continues to advance in the realm of data privacy, with the ambitious goal of achieving zero data breaches. The Personal Data Protection Committee (PDPC), an independent government body established by the Personal Data Protection Act (PDPA), is taking a more proactive approach, having published several rulings and orders to enhance data protection measures and clarify compliance expectations for businesses. Here is a look back at Thailand’s data privacy developments in the first half of the year. Strengthening Law Enforcement and New Guidance for Compliance Enforcement of existing data protection laws and regulations has taken a step forward this year. Some of the specific initiatives include: Increased enforcement by the PDPC. A key trend to watch from the first half of 2025 is the PDPC’s active enforcement of the PDPA as it intensifies oversight through compliance orders and public warnings against noncompliant organizations while ramping up efforts to prevent and halt the illegal trading of personal data by actively monitoring emerging societal issues. Call center scams and cyber fraud control. Thailand published an amendment to the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes to strengthen measures against technological crimes, particularly targeting call center scams and cyber fraud. Orders from the Expert Committee. Several orders issued by the Expert Committee under the PDPA were announced in the first half of this year. These include directives for data controllers to take corrective actions to comply with the PDPA, as well as initiatives to raise awareness of data privacy within organizations, reflecting the regulator’s focus on promoting organizational awareness and compliance. A guideline report summarizing the Expert Committee’s decisions and orders was also published to serve as a reference for compliance. Public issue monitoring. The PDPC has been taking a more proactive approach

Three American giants are actively protecting their intellectual property rights against generative AI, as two legal battles commence on both sides of the Atlantic. In the UK, Seattle-based media company Getty Images accuses UK-based Stability AI of multiple IP infringements. In the US, The Walt Disney Company and Universal Studios are teaming up against Midjourney, an AI startup, with their main ground being copyright infringement. Both cases are centered around questions legal minds have been posing since the introduction of generative AI: Is the output of generative AI an infringement? And who is ultimately responsible for the output, the platform or the user? Getty Images v. Stability AI Getty initially filed a claim in the High Court in 2023, which resulted in Stability applying for reverse summary judgment on the grounds that Getty had no real prospect of success, arguing that their operations took place outside the UK. However, the High Court judge hearing the case decided that the claims brought by Getty did have a real prospect of succeeding in court. Despite this, Stability saw a small victory when the court ruled that the representative action brought by Getty would not succeed due to the difficulties in identifying who qualified for the class. The proposed class was comprised of 50,000 rightsholders who alleged their rights were also infringed. Stability was successful in arguing that identifying these individuals would be challenging due to the unclear definition of the class. This current trial is centered around four main grounds: Copyright infringement. Getty accuses Stability of using content that Getty owns or has an exclusive license for when training their model, Stable Diffusion, resulting in the generated output containing substantial parts of that content. Getty is also alleging secondary copyright infringement, arguing that Stability is importing an article into the UK

Vietnam’s new Personal Data Protection Law (PDPL) was passed by the National Assembly on June 26, 2025, and will enter into force on January 1, 2026. The PDPL introduces several new concepts, exemptions, and obligations in comparison with the current Decree No. 13/2023/ND-CP on personal data protection (PDPD), while other contents remain essentially the same. The relationship between the PDPD and the PDPL has not been clearly addressed; however, it is expected that the government will issue a new decree providing necessary guidance on certain requirements under the PDPL, and the PDPD will remain in effect until it is replaced by this new decree. Some key points of the new PDPL include the following: Personal data will be further defined by lists of basic personal data and sensitive personal data to be issued by the government. The consent-centric approach of the PDPD remains in place, along with additional exemptions for certain data processing activities. The requirements for the data processing impact assessment (DPIA) and transfer impact assessment (TIA) remain unchanged. However, there are new exemptions for the TIA, including for the processing and storing in the cloud of employee data, and when the data subject is the person sending its own data outside of Vietnam. Consent obtained under the PDPD remains valid under the PDPL. DPIAs and TIAs submitted under the PDPD are valid under the PDPL but may need to be updated to be in line with the requirements of the PDPL. Administrative fines depend on the type of violation. The fine for sale and purchase of personal data will be 10 times the revenue from the sale or VND 3 billion (about USD 115,000), whichever is higher. The fine for cross-border transfer violations is 5% of the violator’s revenue of the preceding year or VND 3 billion,