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April 9, 2026

Thailand’s Public Consultation on Proposed PDPA Guidelines: Key Updates

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As part of its ongoing public consultation process for the development of new practical guidelines under the Personal Data Protection Act B.E. 2562 (2019) (PDPA), Thailand’s Personal Data Protection Committee (PDPC) held a two‑day public hearing on April 1–2, 2026. The hearing followed an online questionnaire and stakeholder engagement activities conducted in March 2026 and reflects the PDPC’s continued efforts to develop guidance that aligns international regulatory standards with Thai operational realities.

The public hearing provided a forum for participants from both the public and private sectors to exchange views with the PDPC on the proposed guidance so that it responds to the needs of the business community while supporting effective and balanced enforcement of the PDPA. The PDPC emphasized that the consultation process is part of a wider policy objective to build trust in the convenient, secure, and internationally aligned exchange of data.

Structure of the Consultation Process

According to the PDPC, the initiative to develop the draft PDPA guidelines is being implemented through three core phases:

  • Review of international best practices. The PDPC has conducted a comparative review of data protection guidance and regulatory approaches in jurisdictions with internationally recognized standards, including Singapore, the United Kingdom, the European Union (EU), and Japan. These materials are intended to serve as a reference point for developing practical recommendations across key subject areas under the PDPA.
  • Identification of practical issues and challenges. To ensure that the guidelines respond to real‑world compliance challenges in Thailand, the PDPC has gathered views from a broad range of stakeholders across the public sector, the private sector, and the general public. This phase included focus group discussions and questionnaires aimed at identifying areas to provide organizations with greater clarity and consistency on regulatory expectations.
  • Preparation of draft guidelines. Insights from the comparative study and stakeholder feedback are being consolidated to prepare draft guidance covering six core thematic areas (see the following section), intended to reflect both international standards and the practical realities of PDPA implementation in Thailand. The input gathered will be used to inform a draft set of guidelines.

Overview of Draft Guidelines

The consultation process has now advanced beyond open‑ended issue identification, with the PDPC presenting substantive draft guidelines that provide clearer insight into the regulatory focus of the six core thematic areas:

  • Lawful basis for processing personal data. The draft guidelines clarify the importance of lawful basis and lay out how organizations should identify, assess, and document lawful bases for the collection, use, and disclosure of personal data. They emphasize necessity, proportionality, and accountability and address both general and sensitive personal data, supported by practical examples, checklists, and FAQs.
  • Security measures and personal data breach notification. To address this area, the draft guidelines set out a structured framework for security measures, covering technical, administrative, and physical measures, as well as consideration for conducting data protection impact assessments (DPIAs) and managing risks arising from third parties and data transfers. They further provide detailed operational guidance on identifying and assessing personal data breaches, determining notification obligations, incident response procedures, documentation, and timelines for notifying the Office of the PDPC and affected data subjects.
  • Data protection officers (DPOs). The draft guidance clarifies when an organization is required to appoint a DPO and sets out expectations regarding the DPO’s role, professional qualifications, independence, reporting lines, and avoidance of conflicts of interest. It also includes checklists for key compliance concerns, such as the appointment process, the DPO’s position within the organization, and accessibility to data subjects and the Office of the PDPC.
  • Marketing and direct marketing. These guidelines also set out relevant data protection principles for the use of personal data for marketing and direct marketing purposes, such as purpose limitation, data minimization, lawful bases for processing, and applicable data subject rights. They categorize different types of marketing activities (including direct marketing, online tracking, profiling, and platform‑based targeting), provide practical organizational procedures on transparency, opt‑out mechanisms, and consent withdrawal, and provide illustrative case studies and FAQs on common marketing scenarios.
  • Records of processing activities (ROPAs). The draft ROPA guidelines position ROPAs as a core accountability and compliance tool, highlighting mandatory content, the roles of controllers and processors, and a structured approach to preparation, review, and updating ROPAs. This includes practical examples (e.g., HR, customer management, IT vendors, CCTV), templates, and a questionnaire for gathering information within the organization for filling in the ROPA.
  • Use of CCTV and access control systems. The guidelines address personal data processing involving CCTV and related surveillance technologies in housing estates and condominiums, with the objective of promoting PDPA‑compliant, industry‑consistent practices. Also covered are common risk areas, such as visitor management, biometrics, license plate recognition, and resident portals, as well as practical guidance and FAQs for typical operational scenarios.

Regulatory Signals

The April 1–2 public hearing indicates that the PDPC is moving into a more mature, internationally informed phase of PDPA guidance development while remaining attentive to domestic operational challenges. Although the forthcoming guidelines will not have the force of law, they are expected to influence regulatory expectations, compliance assessments, and enforcement decisions.

Organizations should therefore anticipate greater clarity but not a relaxation of PDPA obligations, and may wish to begin reviewing current compliance frameworks, particularly in higher‑risk processing areas, internal documentation practices, and governance arrangements, in preparation for the final guidance.

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