Vietnam’s draft Personal Data Protection Law (PDPL) continues to evolve, with significant implications for businesses operating in the region. The latest draft, released to the public in March 2025, contains several noteworthy changes from the previous draft that businesses with operations in Vietnam should be aware of when developing their data protection strategies and compliance frameworks. The draft PDPL will be submitted to the vote of the National Assembly in May 2025 with a tentative entry into force on January 1, 2026. Key Changes in the Latest Draft PDPL 1. Redefined Categories of Personal Data The draft PDPL has made important revisions to personal data classifications: Basic personal data: An individual’s image is no longer classified as basic personal data. Sensitive personal data: Bank account information has been removed from this classification (and is now considered basic personal data), but two new categories have been added: (i) salary, allowances, and other income sources, and (ii) information on land users and information on land containing such information. Organizations should review their data classification schemes and update protection measures accordingly, particularly for salary and compensation information. 2. Data Encryption Requirements The draft PDPL explicitly states that encrypted data remains classified as personal data. Additionally, it mandates that sensitive personal data must be encrypted when stored, transmitted, received, or shared in cyberspace. Organizations and individuals can freely opt for one or more encryption solutions and encryption/decryption processes suitable for their personal data management and administration activities. 3. Biometric Data Processing The latest draft PDPL adds new protection requirements for biometric data. Organizations processing biometric data (such as fingerprints) must: Implement physical security measures for devices storing and transmitting biometric data. Use strong encryption methods during transmission and storage. Restrict access to biometric data. Have early-detection monitoring systems to detect violations of biometric

After making revisions to the initial draft notification released in November 2024, Thailand’s Electronic Transactions Development Agency (ETDA) has released an updated draft Notification on Additional Obligations for Digital Platform Service Operators of Online Marketplaces for Goods with Specific Characteristics under Section 18(2) of the Royal Decree on the Operation of Digital Platform Service Businesses Subject to Prior Notification B.E. 2565 (2022) B.E. … . A focus group session was also held to gather feedback from business operators. Below is a summary of key provisions in the new draft. Unchanged Items Some key concerns that remain unchanged from the previous version of the draft notification include the following: Offshore business operators running online marketplaces that act as intermediaries for the sale or exchange of goods and provide facility services for the sale of goods (referred to as “specific marketplace operators” in the draft) are required to establish a local entity in Thailand. However, the criteria for determining which operators are specific marketplace operators are still under discussion due to feedback from business operators. Specific marketplace operators must submit a compliance report to the ETDA along with their annual report each year. Specific marketplace operators must verify that “business users” (e.g., merchants) provide complete details about goods in accordance with product standardization requirements. Removed Obligations The updated draft notification has removed specific marketplace operators’ obligations to: Conduct Identity Assurance Level 2 (IAL2) verification of business users before onboarding them on their platforms. Submit a registry of business users’ information to the ETDA. Retain business users’ information for a specified retention period. Implement measures to filter reviews of products subject to specific standards. Revisions Key revisions made to the draft notification include the following: The effective date has been extended to 120 days after the notification’s publication in the Government Gazette,

On February 6, 2025, the prime minister of Vietnam, Pham Minh Chinh, chaired an online meeting to review the progress of Vietnam’s digital transformation agenda. The meeting assessed achievements under the National Digital Transformation Program and Project 06 on the development and application of population data, electronic identification, and authentication for national digital transformation for the period 2022-2025, with a vision to 2030, approved by the prime minister in 2022. The meeting also outlined key legislative and regulatory priorities for 2025, as set forth in Notice No. 56/TB-BPCP issued by the Government Office on February 23, 2025 (Notice 56). One of the central focuses of the 2025 digital transformation agenda is the development and issuance of laws and regulations governing digital technology, data management, and cybersecurity. Below are the key legal developments provided in Notice 56 that stakeholders should anticipate in the coming months. 1. Law on Digital Technology Industry The Ministry of Information and Communications (MIC) has been tasked with finalizing the draft Law on Digital Technology Industry (DTI Law) for submission to the National Assembly at its 9th session in May 2025. This law is expected to establish a comprehensive legal framework for the digital technology sector, addressing regulatory gaps in emerging fields such as artificial intelligence (AI), Internet of Things (IoT), cloud computing, big data and platform services to promote innovation, ensure data security, and support the growth of the digital economy in Vietnam. Concurrently, the MIC will expedite the issuance of guiding decrees to ensure the swift implementation of the DTI Law once enacted. 2. Law on Personal Data Protection and regulations guiding implementation of Data Law The Ministry of Public Security (MPS) is making efforts to finalize the long-anticipated Law on Personal Data Protection (PDPL)—data protection is currently governed by Decree No. 13/2023/ND-CP on

Tilleke & Gibbins has contributed the Cambodia, Myanmar, Thailand, and Vietnam chapters to Data Protection and Cybersecurity Regulation in Southeast Asia, a wide-ranging guide published by Drew Network Asia (DNA). The resource provides a comprehensive overview of data protection and cybersecurity laws across the region, offering practical insight into compliance requirements and regulatory developments affecting organizations that handle personal data or operate digital services in Southeast Asia. The guide begins with a regional overview, including the broader ASEAN context and cooperation initiatives. Jurisdiction-specific chapters follow a consistent structure—covering data privacy and governance obligations, security requirements and breach notification, outsourcing and cross-border data transfers, and broader accountability and compliance measures. This format allows readers to compare regulatory approaches across markets such as Brunei, Indonesia, Malaysia, the Philippines, Singapore, and others. In addition to the country chapters, the publication addresses cybersecurity and privacy engineering challenges, providing guidance for organizations and outlining obligations applicable to data controllers, processors, and intermediaries. A dedicated section on data breach management across ASEAN examines notification requirements, response considerations, and practical steps for managing incidents in a regional or global context. The guide is intended to serve as a practical reference, and the authors note that specific legal requirements may vary depending on sector, processing activity, or evolving legislation. Readers seeking more detailed advice can contact the practitioners listed in each chapter. The full guide is available for download using the button below or directly from the DNA website.