SQEP-led, independent cyber resilience for Singapore CII and enterprise across APAC
SQEP-led, independent cyber resilience for Singapore CII and enterprise across APAC
A named, outsourced Data Protection Officer on a monthly retainer. Policies that match what you really do, a personal data inventory, breach readiness and a contact the public and the regulator can reach, for organisations that must have the role but not a full-time hire. One part of a wider security and compliance programme. PDPA, PDPC guidelines, Data Protection Trustmark, ISO/IEC 27701.
DPO-as-a-Service (an outsourced Data Protection Officer) gives your organisation a qualified person, outside your payroll, who is designated as your Data Protection Officer: a named contact for customers, staff and the Personal Data Protection Commission, and a privacy programme with owners and dates. Singapore's Personal Data Protection Act requires every organisation to designate at least one individual responsible for its compliance and to make that person's business contact information available to the public. The Commission's guidelines state that the DPO need not be an employee. Legal responsibility stays with the organisation. Infracom supplies the named DPO, backed by a certified security team. Data protection is one part of your security and compliance programme: the DPO holds the personal data part, and the rest sits with the other Infracom services shown below.
Data protection is one part of a wider programme. The Data Protection Officer looks after personal data under the PDPA. The security that protects that data is built, tested and audited by the other Infracom services, so the DPO is never working alone.
Set the rules, close the gaps and keep the programme running.
GRC consulting →Policies, risk and the framework your customer or regulator names.Fractional CISO →Runs your whole security programme.Fractional Chief AI Officer →Runs the governance of your AI.Prove on the real systems that the controls hold.
VAPT →Certified testers attack your systems and report what they find, then retest the fixes.SQEP testing and go-live endorsement →For Government and critical infrastructure systems, the test scope and the go-live are endorsed.An independent opinion your board, customers and regulators can rely on.
Internal audit →Checks the running programme against the standard, reading the test report as evidence.Supplier audit →The same check on the vendors you depend on.One rule holds from start to end: the people who build do not test, and the people who build or test do not give the opinion. See how Infracom keeps the three apart →
The same three jobs an in-house DPO holds: govern, respond and embed. The difference is the cadence. Hours are fixed each month, the security team behind the DPO is already certified, and nothing waits for a hire.
The DPO builds and keeps the data protection management programme: what personal data you hold, why, where it goes, who answers for it, and what management is told. The security controls that protect that data are built with GRC consulting or your fractional CISO.
Queries, complaints, access and correction requests and suspected breaches all reach one accountable person, who knows the timelines the law sets and keeps the record. In a breach, the technical investigation is done by Infracom's security team and the DPO handles the assessment and the notification.
New systems, new vendors and new uses of data are checked before they go live, and the people who handle personal data know what is expected of them. Systems that hold personal data are tested by the VAPT team, and vendors that handle it are checked through a supplier audit.
The duty to have a DPO applies to every organisation, whatever its size. These are the situations where a named DPO on retainer is the right answer.
The Personal Data Protection Act requires every organisation to designate one or more individuals to be responsible for its compliance, and to make the business contact information of at least one of them public. Many smaller firms name a director or the office manager, who has no time and no training for it. An outsourced DPO holds the role properly, with the hours it needs.
Customer data sits under both the Personal Data Protection Act and the MAS Technology Risk Management Guidelines. One team that runs the privacy programme and the security controls together keeps one evidence base for both, instead of two advisers who do not speak to each other.
Clinics, schools, charities, employers and membership bodies hold the kinds of data whose loss is likely to cause significant harm. A breach of that kind must be assessed quickly and, where it is notifiable, reported to the Commission within three calendar days and to the people affected. A DPO who has prepared the plan in advance is what makes those timelines achievable.
A software or outsourcing provider that handles personal data on a client's behalf is a data intermediary. It must protect the data, keep it no longer than needed and tell its client of a breach without undue delay, and its clients will ask for proof before they sign. A named DPO, a data inventory and tested procedures answer those due diligence questionnaires.
The Commission's Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems set out how consent, notification and accountability apply when personal data trains or feeds an AI system. The DPO reviews each AI use of personal data, working with Infracom's fractional Chief AI Officer service where the organisation needs AI governance as a whole.
Personal data may leave Singapore only where the recipient is bound to a comparable standard of protection, by law, contract, binding corporate rules or a recognised certification. The DPO maps the transfers and puts the right mechanism behind each one.
Three shapes. Most organisations start with the foundation project and move to a retainer once the programme exists. Hours per month are agreed at scoping and can change with the organisation.
A fixed project. Gap assessment against the Personal Data Protection Act, personal data inventory and data flow map, policies and notices, retention schedule, breach response plan and the public DPO contact set up. For organisations starting from little or nothing. Where the wider security programme is also missing, it is built alongside through GRC consulting.
A named Infracom consultant is designated as your Data Protection Officer. Query and complaints desk, access and correction requests, impact assessments, staff training, a quarterly management report, and breach assessment and notification support when it is needed. Once a year the programme is checked by an internal audit, carried out by auditors who took no part in it.
For organisations whose DPO is an employee. A senior adviser on call for difficult requests, impact assessments, vendor and overseas transfer reviews, AI use reviews, and readiness for the Data Protection Trustmark or ISO/IEC 27701.
↔ Swipe to compare
| Dimension | Outsourced DPO (Infracom) | An employee named as DPO | Legal advice alone |
|---|---|---|---|
| Named accountable person | Yes, designated in writing, contact published, reports to your management | Yes, usually on top of another full-time job | No, a lawyer advises on the law but does not hold the role |
| Time for the role | Fixed hours each month, set at scoping | Whatever is left after the day job | Engaged case by case |
| Security depth | Backed by a certified security team: the controls that protect the data are assessed by the people who test them | Depends on the individual | Outside the scope of legal advice |
| When a breach happens | A prepared plan, a named lead, and technical investigation from the same firm | Often the first time the plan is read | Advice on notification; the investigation is someone else's |
| Continuity | A team behind the named DPO; cover is built in | Resignation or leave leaves the role empty | Not applicable |
| Best fit | Most organisations without a privacy team pair an outsourced DPO with their own lawyers: the DPO runs the programme day to day and the lawyers are called for contracts and disputes. Where an employee already holds the role well, DPO Advisory gives that person a senior second opinion. In every case the organisation itself stays legally responsible for its compliance. | ||
Sources: Personal Data Protection Act 2012 and the Personal Data Protection (Notification of Data Breaches) Regulations 2021; Personal Data Protection Commission, Advisory Guidelines on Key Concepts in the PDPA and Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems (pdpc.gov.sg); Infocomm Media Development Authority, Data Protection Trustmark (imda.gov.sg). Obligations depend on your organisation and the data it holds; confirm with the issuing authority or your legal adviser before relying on this comparison.
The same methodology as every Infracom GRC engagement, on a monthly rhythm. The first ninety days build the baseline; after that the programme runs and management sees it.
What personal data you collect, where it is kept, who it is shared with and what is already written down, reviewed against the obligations of the Personal Data Protection Act.
The DPO is designated in writing, the business contact is published where the public can find it, and staff know where to send a request or a concern.
The data inventory, the policies and notices, the retention schedule and the breach response plan are built around how the organisation really works, not copied from a template.
Fixed hours each month: requests and complaints answered, new projects and vendors checked, training delivered, and a short written note of what was handled.
Management receives the requests, incidents, open risks and changes in the law each quarter. Once a year the inventory and policies are reviewed, the breach plan is exercised, the systems holding personal data are tested and the programme is audited.
If you later appoint an employee as DPO, the inventory, the policies and the records transfer in full. Nothing is locked to Infracom.
What the law asks for, who stays responsible, and how the role works beside your security and AI leadership.
Tell us your sector, size and the personal data you hold. A certified consultant will respond within 1 business day with a scoping call and a proposal.
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