Thailand’s Personal Data Protection Act (PDPA) has reshaped the way organizations handle personal data. For foreign companies that collect, use, or disclose the personal data of individuals in Thailand, one important requirement under Article 37 is the appointment of a Data Protection Representative (DPR). This role ensures accountability, transparency, and compliance with Thai law—even when the organization itself is not physically located in Thailand.
What is a Data Protection Representative (DPR)?
A Data Protection Representative acts as a local point of contact between the foreign organization, Thai data subjects, and the Office of the Personal Data Protection Committee (PDPC). In essence, the DPR is the “face” of the organization in Thailand for all matters related to data protection.
Why is it Required?
Article 37 of the PDPA requires foreign organizations that process personal data of Thai residents to designate a DPR. This applies if the organization:
- Offers goods or services to individuals in Thailand, or
- Monitors the behavior of individuals within Thailand.
The rationale is straightforward: Thai data subjects and regulators must have an accessible way to communicate with foreign companies that are impacting their data privacy rights.
Key Responsibilities of a DPR
A Data Protection Representative is expected to:
- Act as a liaison with the PDPC on compliance matters.
- Facilitate communication with Thai data subjects exercising their PDPA rights.
- Help Maintain records of processing activities, ensuring transparency.
- Support accountability by helping the organization demonstrate compliance.
Why Foreign Organizations Should Take This Seriously
Failing to appoint a DPR when required can expose foreign companies to significant risks:
- Regulatory penalties for non-compliance.
- Loss of trust among Thai customers and partners.
- Operational disruptions if the organization cannot effectively handle data subject requests or regulator inquiries.
Beyond avoiding penalties, having a DPR also helps build trust and credibility for businesses operating in Thailand. It signals that the organization takes data privacy seriously and respects the rights of individuals.
Conclusion
For foreign organizations under the scope of Thailand’s PDPA, appointing a Data Protection Representative (DPR) is not just a legal formality—it is a strategic step. A qualified DPR ensures compliance, strengthens trust, and provides a vital bridge between the organization, Thai regulators, and local data subjects.
At Data Excellium, we serve as DPR for leading organizations across industries, helping them stay compliant while building trust in the Thailand. If you need guidance or representation under the PDPA, reach out to us—we’re here to help.