# PDPC Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems

- **Record type**: Policy instrument
- **Jurisdiction**: Singapore
- **Instrument type**: Guidance
- **Status**: Guidance
- **Binding**: No — guidance, strategy or standard
- **Issuing body**: Personal Data Protection Commission Singapore
- **Adopted**: 2024-03-01
- **Published**: 2024-03-01

## In brief

The PDPC AI advisory guidelines is a non-binding guidance of Singapore, issued by the Personal Data Protection Commission Singapore. Its current status is guidance. Organisations subject to the PDPA that use personal data in AI recommendation and decision systems, and service providers developing such systems for them. 2 obligations are recorded against it, each with its source reference.

## Summary

These advisory guidelines explain how the Personal Data Protection Act applies when organisations use personal data to develop, test and deploy AI systems that make recommendations, predictions or decisions. They clarify the consent obligation and relevant exceptions (business improvement and research), what to include in notifications to individuals, accountability practices such as documenting data provenance and model development, and expectations for service providers building bespoke AI systems.

## Scope

Organisations subject to the PDPA that use personal data in AI recommendation and decision systems, and service providers developing such systems for them. Advisory; not legally binding, but reflects how the PDPC interprets binding PDPA obligations.

## Who it applies to

PDPA-regulated organisations and their AI service providers.

## What organisations must do

Identify the legal basis for using personal data in AI (consent or an exception), provide notification about the AI's use of personal data, and document data-protection and governance practices across the AI lifecycle.

## Key dates

Issued 1 March 2024 following a 2023 public consultation.

## Penalties

Underlying PDPA breaches can attract financial penalties up to 10 % of annual turnover in Singapore or SGD 1 million, whichever is higher.

## Obligations recorded against this instrument (2)

- **Identify consent or an applicable PDPA exception before using personal data in AI** (Advisory guidelines, sections on consent, business improvement and research exceptions) — Personal data used to train or operate AI systems requires consent unless an exception applies, such as the business improvement exception for improving products and services or the research exception for developing models, each subject to conditions.
  - Binding: yes
  - Record: https://aipolicytracker.org/obligations/singapore-pdpc-consent-or-exception-for-ai-data
- **Notify individuals about the use of personal data in AI recommendations and decisions** (Advisory guidelines, section on notification obligation) — Organisations should inform individuals that AI systems use their personal data, the purposes, the relevant features and how they influence decisions, proportionate to the impact on the individual.
  - Binding: yes
  - Record: https://aipolicytracker.org/obligations/singapore-pdpc-ai-notification

## Provenance

- **Permanent id**: AIPT-POL-0171 (https://aipolicytracker.org/id/AIPT-POL-0171; never changes or gets reused)
- **Record page**: https://aipolicytracker.org/policies/singapore-pdpc-ai-advisory-guidelines
- **Official source**: https://www.pdpc.gov.sg/guidelines-and-consultation/2024/02/advisory-guidelines-on-use-of-personal-data-in-ai-recommendation-and-decision-systems
- **Source document**: Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems
- **Published by**: Personal Data Protection Commission Singapore
- **Review status**: verified
- **Confidence**: medium
- **Facts last confirmed**: 2026-09-26
- **Confirmed by**: Bhaskar Bhatt (see https://aipolicytracker.org/reviewers)
- **Retrieved**: 2026-10-27
- **Licence**: https://creativecommons.org/licenses/by/4.0/
- **Cite as**: AIPolicyTracker (2026). "PDPC Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems" [AIPT-POL-0171, record version 1, verified 26 September 2026 by Bhaskar Bhatt]. https://aipolicytracker.org/id/AIPT-POL-0171 (accessed 27 October 2026).

> This record is a structured summary with a link to the official text. It is not legal advice. Open the official source before relying on any date or duty. How current each record type must be is published at https://aipolicytracker.org/verification; what a record must carry at all is published at https://aipolicytracker.org/coverage.