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

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 INSIGHTS​ 

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
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
July 24, 2025
Vietnam’s Ministry of Public Security recently released a draft version of the 2025 Cybersecurity Law, which is intended to replace both the existing 2018 Cybersecurity Law and the 2015 Law on Network Information Security (LNIS). This consolidation reflects a broader effort by the Vietnamese government to streamline and centralize the legal framework governing cybersecurity, data protection, and information security to be under the sole authority of the Ministry of Public Security, moving away from the previous sharing of responsibility with the former Ministry of Information and Communications (which ceased operations earlier this year and merged with the Ministry of Science and Technology). This shift aims to eliminate overlaps and improve enforcement efficiency. The draft law is built upon the foundation of principles and provisions of both the 2018 Cybersecurity Law and the 2015 LNIS, while also introducing a wide range of amendments and new regulations. By merging the two laws, the government seeks to reduce legal fragmentation and ensure consistency in definitions, obligations, and enforcement mechanisms across related domains like data protection, IT system classification, and cybercrime prevention. The newly introduced amendments include enhanced obligations for service providers, stricter controls on information transmission, classification of IT systems, designation and protection of nationally important information systems, and sector-specific violations and compliance requirements. Highlights of the draft law are discussed below. Definition and Obligations of Service Providers The draft law clearly defines and significantly broadens the scope of entities considered “service providers” under its jurisdiction. This now includes businesses and individuals offering products or services in cyberspace, including both infrastructure and content online services, such as: Internet service providers (ISPs) and providers of telecommunications, hosting, servers, domain names, VPNs, proxy services, and cloud computing; Providers of social networks, websites, and online gaming; Financial institutions, banks, foreign bank branches in Vietnam, e-wallet
July 23, 2025
On July 4, 2025, Thailand’s Electronic Transactions Development Agency (ETDA) issued two significant notifications that introduce new compliance requirements for ride-hailing platforms operating in the country. The notifications formally designate these platforms as high-impact digital services under section 18(3) of the Royal Decree on Digital Platform Service Businesses and impose a comprehensive set of additional operational obligations. These measures are designed to address regulatory gaps and enhance oversight of digital platforms providing public passenger vehicle or motorcycle ride-hailing services. First, the Notification on the Designation of Ride-Hailing Platforms under section 18(3) formally designates all ride-hailing platforms that have notified the ETDA of their operations as high-impact digital platform services under section 18(3) of the royal decree. Unlike high-risk marketplace platforms, which are named individually, any ride-hailing platform that has notified the ETDA of its operations is automatically subject to these new requirements. Next, the Notification on Additional Obligations for Ride-Hailing Platforms imposes further obligations on ride-hailing platforms, supplementing the general requirements under section 21 of the royal decree. These notifications will come into force 90 days from their publication in the Government Gazette. New Compliance Obligations The new regulatory framework introduces a range of operational, technical, and reporting requirements for ride-hailing platforms, particularly concerning the issues described below. Vehicle and Driver Compliance Operators must: Ensure that all vehicles used on the platform are registered as public vehicles in accordance with Department of Land Transport requirements Verify all drivers hold valid public driving licenses Collect service fees in compliance with applicable fare regulations under the Vehicle Law Digital Platform Features and User Verification Operators must implement robust digital platform features for both drivers and riders, including: Comprehensive identity verification and confirmation processes for drivers and riders, utilizing both face-to-face and non-face-to-face methods, including biometric and digital ID checks Real-time GPS