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 25, 2025
Artificial intelligence (AI), semiconductors, and digital assets are considered critical drivers of Vietnam’s future economic growth and are fundamental to the nation’s digital transformation targets. These sectors form the core of Vietnam’s strategy to build a robust, globally competitive digital economy. This strategic direction gained substantial momentum with the issuance of the Law on Digital Technology Industry (DTI Law) on June 14, 2025. The DTI Law was designed to attract investment, stimulate innovation, cultivate high-quality human resources, and ensure the responsible, secure, and sustainable growth of digital technologies like AI and digital assets, harmonizing Vietnam’s digital industry with international standards while safeguarding public interests and national security. Several key provisions of the DTI Law took effect on July 1, 2025, and the law will become fully effective on January 1, 2026. The government is delegated to provide further necessary guidelines and details for implementation of the law. Artificial Intelligence (AI): Principle-Driven and Risk-Based Regulations Under the DTI Law, there are seven core principles guiding the development, provision, and use of AI which are applicable to AI developers, providers and deployers. These principles favor values-based governance over purely technical prescriptions, and include the following: Taking a human-centered approach that upholds ethical values, inclusivity, flexibility, equality, and non-discrimination. Ensuring transparency, accountability, and explainability, with AI systems remaining under human control. Maintaining cybersecurity and system safety. Adherence to data protection and privacy regulations. Having the ability to control AI algorithms and models. Effective risk management throughout the entire lifecycle of AI systems. Compliance with consumer protection laws and other relevant legal frameworks. AI system management follows a risk-based approach, with the law categorizing systems into high-risk, high-impact, and other groups. High-risk AI systems are those that, in certain applications, may pose significant threats or harm to individuals or the public interest while
Read More
August 21, 2025
On August 19, 2025, the Trade Competition Commission of Thailand (TCCT) released its draft Guidelines on the Consideration of Unfair Trade Practices and Conduct Constituting Monopoly, Reducing Competition, or Restricting Competition in Multi-Sided Platform Businesses in the Category of Digital Platforms for the Sale of Goods or Services (E-commerce). A public comment period on the guidelines is open until September 18. The draft provides the first detailed framework for how the TCCT will interpret and enforce the substantive provisions under the Trade Competition Act against digital platforms, which have a unique network effect and require complex competition analysis. This development will profoundly impact the operations of e-commerce platforms, sellers, and associated service providers in Thailand. The guidelines primarily target e-commerce digital platform business operators, which are defined as follows: E-commerce digital platform: A medium facilitating the sale, purchase, or exchange of goods or services, including any operations to create transactions or interactions between business operators via an electronic transaction system, regardless of whether service fees are charged. E-commerce digital platform business operator: A service provider of a digital platform for the sale of goods or services who acts as an intermediary facilitating the sale of goods or services, including any operations to create transactions or interactions through an electronic transaction system by receiving orders for goods or services transacted via an electronic system, whether in the form of an e-marketplace, a social marketplace, or any other form that connects purchase orders for goods or services with business operators through an electronic system. Prohibited Conduct The guidelines classify potentially anticompetitive conduct and unfair trade practices into two categories: price-related and non-price-related conduct. 1. Price-related conduct The TCCT is targeting pricing strategies that can harm competition. Key prohibited behaviors include: Price below cost: Setting prices below the average total cost without
Read More
August 21, 2025
On August 18, 2025, Thailand’s Securities and Exchange Commission (SEC), in collaboration with the Ministry of Finance, the Anti-Money Laundering Office, and the Ministry of Tourism and Sports, announced the launch of TouristDigiPay. The initiative, implemented under the SEC’s Regulatory Sandbox, allows foreign tourists to convert digital assets into Thai baht for use in everyday transactions in Thailand. Foreign tourists who opt to participate in TouristDigiPay must open two accounts once they are in Thailand: An account with a licensed digital asset operator to sell or exchange digital assets for Thai baht; and A tourist wallet account with a licensed e-money operator regulated by the Bank of Thailand. Funds from digital asset sales will be transferred into the tourist wallet, enabling tourists to make payments at participating merchants that accept e-money. Key Regulatory Requirements The TouristDigiPay project will operate for a period of up to 18 months, with the following conditions: Only licensed digital asset brokers, dealers, and exchanges integrated with licensed e-money operators are eligible to participate. Operators must implement anti-money laundering (AML) protocols that are proportionate to the assessed risk level. These include: Conducting know-your-customer and customer-due-diligence (KYC/CDD) checks on all users. For monthly transactions exceeding THB 50,000 per person, verifying the source of the digital assets and assessing AML risk using internationally recognized blockchain forensic tools or equivalent procedures. Suspending or rejecting services if digital assets are transferred from wallets flagged for AML concerns. Ensuring that conversion between digital assets and fiat includes safeguards such as matching account names and returning digital assets only to the original wallet. The following transaction limits apply to participants in the TouristDigiPay initiative: Payments to small vendors are capped at THB 50,000 per month. Payments to vendors who have completed the know-your-merchant (KYM) process are capped at THB 500,000 per
Read More
August 15, 2025
More than a decade after the issuance of Decree No. 52/2013/ND-CP (as amended by Decree No. 85/2021/ND-CP; collectively, “Decree 52”), Vietnam’s legal framework for e-commerce is under growing pressure to keep pace with the evolving digital economy. While Decree 52 has provided a foundational framework, it has shown certain limitations in keeping up with issues such as counterfeit goods, intellectual property enforcement, unqualified products, and emerging models like livestream selling and affiliate marketing. To address these regulatory gaps, the Ministry of Industry and Trade (MOIT) has released the 2025 Draft E-Commerce Law (“Draft Law”) for public consultation. The Draft Law is intended to supersede the current framework under Decree 52 and establish a more detailed and comprehensive legal foundation for the regulations of e-commerce activities in Vietnam. It is currently expected to be submitted to the National Assembly for review and potential adoption during its 10th session in October 2025. In this article, we discuss the Draft Law’s most significant updates and legal developments in comparison to existing regulations, and assess the practical challenges that businesses may face in preparing for implementation in the near future. Platform Classification: Toward a More Nuanced Framework Unlike Decree 52’s simpler structure, which broadly categorized platforms into either (i) websites selling goods and services or (ii) websites providing e-commerce services, the Draft Law introduces a more detailed framework that aims to classify platforms based on their technical functions and business models. Specifically, the Draft Law introduces a four-tier classification system for e-commerce platforms, consisting of: (i) Direct Business Platforms, (ii) Intermediary Platforms, (iii) Social Networks with E-Commerce Functions, and (iv) Multi-Service Integrated Platforms. This approach reflects an effort to more accurately capture the complexity of today’s e-commerce landscape, including hybrid platforms such as TikTok Shop. While this approach reflects the growing complexity of
Read More