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 20, 2026

Thailand Issues New Rules on Data Subject Access Requests

Subscribe to Updates

On July 16, 2026, Thailand’s Personal Data Protection Committee (PDPC) published a notification in the Government Gazette establishing detailed rules governing data subjects’ right of access under section 30 of the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The notification will take effect 60 days after publication—mid-September 2026—giving data controllers a limited window to bring their processes into compliance.

Scope

The notification covers requests to access or obtain copies of personal data and requests for disclosure of the source of data collected without consent. Data subjects may exercise their rights directly or through authorized representatives.

Key Requirements

Important requirements set by the notification include the following:

  • Required request channels. Controllers must provide at least two request channels: direct submission at the business location and registered mail. Electronic channels are optional but, if offered, may also be used for fulfilling requests.
  • Request contents. Requests must be in writing or in electronic form and include the data subject’s name, the preferred access method, details of the data requested, and the requester’s signature. Controllers may request additional identifying information as needed.
  • Identity and authority verification. Controllers may require official identity documents for verification. Authorized representatives must provide authorization documents and identity documents for both the data subject and the representative. Alternative verification methods (e.g., digital authentication) are permitted if they do not unreasonably obstruct data subjects’ rights.
  • Review and response timelines. Controllers must review requests within 15 days. If the request is incomplete, the controller must notify the requester and allow at least 15 days to correct deficiencies. If not corrected, the request may be treated as abandoned. Once verified, controllers must fulfill requests within 30 days, extendable by another 30 days for large-volume or complex requests with notice to the requester.
  • Methods for providing access or copies. Controllers may fulfill requests by allowing inspection, providing document copies, or granting electronic access. If a request is submitted electronically, the response should also be electronic where possible.
  • Grounds for refusal or limitation. Controllers may refuse requests where permitted by law or court order, where compliance would harm third-party rights (including personal data, trade secrets, or IP), or where the request is manifestly unfounded or unreasonably burdensome. Controllers must provide data subjects with the reason for refusal in writing, and the refusal must be recorded in the controller’s records.
  • Allowable fees. Electronic access without special recording or delivery costs should generally be free. Where fees are permitted, they must be reasonable, not exceed actual costs, and comply with the schedule attached to the notification. Fee details must be disclosed to data subjects in advance of any requests.
  • Recordkeeping. Controllers must retain records of requests and responses for at least two years. Electronic recordkeeping is permitted.
  • Interaction with other laws. Where other laws impose access-related duties, controllers must comply with those laws while remaining consistent with this notification’s procedures.

Next Steps

Data controllers being subject to the PDPA, both onshore and offshore, should assess their current data access request handling procedures against the notification’s requirements, including whether they offer the mandatory request channels and can meet the prescribed timelines. Key actions include:

  • Conducting a gap analysis of existing procedures against the new requirements.
  • Updating privacy notices and internal policies to clearly communicate request channels, fee schedules, and processing timelines.
  • Implementing or updating request management systems to track requests, verification status, deadlines, and record retention.
  • Training relevant personnel, particularly data protection officers, customer service teams, and legal and compliance staff, on the new timelines and procedures.
  • Preparing template responses, including refusal notices with documented reasons, correction requests, and abandonment notifications.

Given the short compliance window, organizations that have not yet established formal data access request procedures should begin implementation promptly.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

August 6, 2025
Thailand’s Digital Government Development Agency (DGA) has released drafts of two pivotal documents to guide Thai government agencies in adopting cloud technology and classifying data for cloud usage. These draft guidelines, open for public hearing through August 12, 2025, are part of the national “Go Cloud First” policy, which aims to accelerate digital transformation, improve efficiency, and ensure robust data security across the public sector. The new standards will have significant implications for both government agencies and cloud service providers operating in Thailand. Highlights of the draft guidelines are presented below. Government Cloud Usage Guidelines Cloud-first transformation: All government agencies are directed to prioritize cloud solutions for new IT projects, in line with the cabinet’s “Go Cloud First” policy. Cloud model selection: Agencies must assess their needs and select the most appropriate cloud deployment model—public, private, hybrid, or community cloud—based on the sensitivity of the data and operational requirements. Service types: The guidelines provide criteria for choosing between Infrastructure as a Service (IaaS), Platform as a Service (PaaS), and Software as a Service (SaaS), emphasizing the importance of using standard, non-customized services where possible. Cost management: Agencies are required to plan and separate cloud-related expenses, ensuring transparency and efficient budget allocation. Cloud migration: The guidelines outline the steps for migrating to the cloud and highlight the role of cloud service providers in facilitating the process, including supporting innovation and enabling smooth exit strategies. Procurement compliance: All cloud procurement must comply with public sector procurement laws and regulations. Only providers meeting government-mandated standards can be selected. Security and shared responsibility: The guidelines clarify the division of security responsibilities between cloud providers and government agencies. While providers manage infrastructure security, agencies remain responsible for data, application, and access controls. Legal framework: Agencies must comply with the Digital Government Administration Act, Cybersecurity
Read More
August 1, 2025
Thailand’s Personal Data Protection Committee (PDPC) announced to the press on August 1, 2025, that it had issued eight new administrative fines under Thailand’s Personal Data Protection Act B.E. 2562 (2019) (PDPA) in five cases of noncompliance by public and private entities. The enforcement actions reflect a growing commitment by the PDPC to penalize noncompliance across all sectors, regardless of organizational type or size. The total amount imposed to date was approximately THB 21.5 million (approx. USD 654,690), underscoring the financial risks tied to PDPA violations. The five cases—one involving a state agency and the remainder in the private sector—are summarized below. Case 1: State Agency Providing Online Services to the Public The order in this case stemmed from a cyberattack on a state agency’s web app, resulting in personal data of 200,000 data subjects being leaked to and sold on the dark web. The software developer was also found to have implemented no privacy by design, lacked an access control system, had no data breach prevention measures, and failed to conduct risk assessments or review existing security measures. Key noncompliance identified: Lack of appropriate security measures Weak password protection No risk assessment or ongoing review of security measures No data processing agreement with software developer that acted as data processor The state agency and the developer were each fined THB 153,120 (approx. USD 4,670). Case 2: Private Hospital This case involved a hospital that engaged an individual contractor to destroy patient medical record documents. However, the contractor stored the documents at their own premises, failed to follow the required destruction protocols, and ultimately used the medical records to wrap sweets, resulting in the leak of over 1,000 records during the destruction process. The contractor also failed to notify the hospital of the data breach. Although there was a
Read More
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