Tilleke & Gibbins has contributed the Vietnam chapter to Data Protection 2025, a comprehensive comparative guide in the Law Over Borders series from Global Legal Post. This Q&A-style resource offers detailed insights into data protection regulations across multiple jurisdictions, serving as an essential reference for organizations managing personal data in today’s global business environment. The Vietnam chapter examines the evolving data protection landscape in Vietnam, including analysis of relevant provisions in the Cybersecurity Law, the Law on Information Technology, and the upcoming Personal Data Protection Decree. The chapter addresses key aspects of data protection through the following topics: Regulatory framework: Analysis of national laws regulating personal data, jurisdictional scope, application to different entities, and regulated data processing activities. Data categories and processing: Overview of regulated personal data types, special categories requiring enhanced protection, and lawful processing requirements. Compliance requirements: Explanation of controller and processor obligations, technical and organizational measures, and data subject rights. Commercial communications and international transfers: Rules governing direct marketing and cross-border data flows. Regulatory oversight: Details on enforcement powers, investigation procedures, sanctions, and remedies for noncompliance. Tilleke & Gibbins also contributed the Thailand chapter to Data Protection 2025. Readers can access the complete Data Protection 2025 guide through Global Legal Post’s Law Over Borders platform.

Tilleke & Gibbins has contributed the Thailand chapter to Data Protection 2025, a newly published comparative guide from Global Legal Post’s Law Over Borders series. This comprehensive Q&A-style resource provides insights into data protection regulations across multiple jurisdictions worldwide, offering valuable guidance for businesses navigating the complex landscape of global data privacy requirements. The Thailand chapter offers a detailed analysis of the country’s data protection framework, with particular focus on the Personal Data Protection Act (PDPA) that came into full effect in 2022. The chapter addresses key aspects of data protection in Thailand through the following topics: Regulatory framework: National laws governing personal data, scope of application, territorial reach, and regulated operations. Data categories and protection: Types of personal data covered, special categories subject to enhanced protection, and processing requirements. Compliance obligations: Requirements for lawful processing, organizational responsibilities, and data subject rights. Marketing and cross-border considerations: Rules for commercial communications and international data transfers. Enforcement mechanisms: Regulatory powers, investigation procedures, sanctions, and remedies for noncompliance. Tilleke & Gibbins also contributed the Vietnam chapter to Data Protection 2025. Readers can access the complete Data Protection 2025 guide through Global Legal Post’s Law Over Borders platform.

As Vietnam continues its government restructuring, including the merging of several key ministries, the country is signaling that mergers of provinces could be next. Conclusion 126-KL/TW of the Politburo and Secretariat, issued on February 14, 2025, sets out several tasks for continuing to streamline the political system in 2025, notably including, among others, the following: Elimination of intermediate administrative levels, and mergers of provincial units: The Government Party Committee is tasked with researching and planning for the elimination of intermediate administrative levels (district levels); reorganizing the commune level with structures, functions, duties, powers, and responsibilities aligned with the new organizational model; and proposing the merging of some provincial administrative units. A report to the Politburo is required by Q3 2025. Reorganization of police structure: The Central Public Security Party Committee is tasked with leading and coordinating the implementation of a three-tier police organization, eliminating the district-level police. Judicial system reforms: The Central Party Committees of the Supreme People’s Court and the Supreme People’s Procuracy are tasked with researching and advising on the organizational model for courts and procuracies, and proposing amendments and supplements to relevant party mechanisms and state laws, with the aim of eliminating the district level. A report to the Politburo is required by Q2 2025. Implications of Merging Provinces The merging of provinces could bring positive impacts as well as new challenges. The expected benefits include: Administrative efficiency and cost saving: Reducing the number of administrative units could lead to more efficient governance and decision-making processes, as well as lower administrative costs due to fewer government offices and personnel. Economic development: Larger administrative areas can benefit from better allocation of resources and infrastructure development. Larger provinces may also attract more investment due to increased economic potential and market size. Improved service delivery: Public services could improve

Vietnam’s Decree No. 147/2024/ND-CP on the management, provision, and use of internet services and online information (Decree 147) was issued on November 9, 2024, and came into effect on December 25, 2024. Decree 147 represents a more stringently regulated digital landscape in Vietnam, creating challenges not only for offshore service providers offering cross-border services but also for onshore providers. As these new regulations impose stricter requirements, particularly in areas like content control, user authentication, data storage, and service license/notification, companies will need to adapt quickly to maintain compliance and minimize legal risks. The following are some of the key topics covered by Decree 147. [Note: Shortly after the issuance of Decree 147, Vietnam began a government restructuring process, with the aim of streamlining the government by consolidating and eliminating various ministries and agencies. Thus, the decree’s references to authorities such as the Authority of Broadcasting and Electronic Information (ABEI) and the Ministry of Information and Communications (MIC) are subject to change.] 1. Cross-Border Information Provision Cross-border information provision is defined broadly as the provision by overseas organizations and individuals of information and online information content services for service users in Vietnam to access or use. This wide-ranging definition encompasses various types of cross-border services, including social network services, online game services, and app store services. However, cross-border provision of online game services remains prohibited under Decree 147 (see further details below). Offshore providers of services on a cross-border basis who lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months (“regulated cross-border providers”) must adhere to stricter requirements. Specifically, they are required to, among other requirements: Notify the relevant authority of their contact information, including the location of the main server providing the service, within 60