Human Risk Management Institute

PDPA 2024: What Businesses Must Do Now

Written by Nur Rachmi Latifa | 20 Jan 2026

The regulatory landscape for personal data protection in Malaysia has entered a new phase. With the passing of the Personal Data Protection (Amendment) Act 2024 (PDPA 2024), businesses can no longer treat data protection as a secondary compliance exercise. Instead, PDPA 2024 elevates personal data governance into a core business responsibility that affects operations, technology, risk management, and corporate reputation. For businesses operating in or connected to Malaysia—whether local enterprises, regional firms, or global organisations—the message is clear: action is required now. The amendments introduce mandatory obligations, higher penalties, expanded rights for individuals, and greater accountability across the entire data lifecycle.

 

Understanding PDPA 2024: Why It Matters to Businesses

The original Personal Data Protection Act 2010 was an important first step in regulating how personal data is handled in commercial activities in Malaysia. However, over the years, the way businesses operate has changed significantly. Digital platforms, cloud services, cross-border data transfers, and increasingly sophisticated cyber threats have become part of everyday business operations. These developments exposed limitations in the old framework, which was not designed to fully address modern data-driven risks.

PDPA 2024 was introduced to close these gaps. By aligning Malaysia’s data protection regime more closely with international standards, the amendments reflect how personal data is now created, processed, and shared across borders and technologies. Approved in July 2024 and granted Royal Assent in October 2024, PDPA 2024 is no longer a future consideration, it is now part of Malaysia’s legal reality and applies to businesses operating within its scope.

For businesses, PDPA 2024 is more than a technical legal update. It marks a shift in regulatory expectations, where compliance is measured not only by written policies, but by real actions and governance. Organisations are now expected to demonstrate accountability, preparedness, and transparency in how they manage personal data—showing that data protection is embedded into operations, decision-making, and risk management, not treated as a box-ticking exercise.

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The Shift to Data Controller: Clarifying Responsibility in PDPA 2024

One of the most significant changes introduced by PDPA 2024 is the replacement of the term “data user” with “data controller.” This is more than a wording update, it reflects a clearer and stronger assignment of responsibility. By adopting internationally recognised terminology, PDPA 2024 removes ambiguity around who is ultimately accountable for personal data processing within an organisation. A data controller is any business that determines how and why personal data is collected, used, stored, shared, or retained, regardless of whether those activities are carried out internally or through third parties.

For businesses, this shift has real and practical consequences. Accountability can no longer be loosely shared or pushed down the operational chain without clear ownership. Regulators will look beyond surface-level compliance and assess how decisions are made, governed, and overseen at an organisational level. In practice, this means:

  • Accountability can no longer be delegated informally to vendors or operational teams
  • Responsibility rests with the organisation that defines the purpose and means of data processing
  • Regulators will assess intent, governance, and oversight—not just isolated operational mistakes

New Direct Obligations for Data Processors

Under the previous PDPA framework, data processors were often seen as supporting parties with limited legal exposure. Responsibility largely sat with the organisation that owned the data, while vendors and service providers operated in the background. PDPA 2024 changes this approach entirely. Data processors such as cloud providers, IT vendors, payroll services, and outsourced operational partners are now explicitly recognised as accountable parties under the law.

With PDPA 2024, data processors have direct statutory obligations to protect personal data from loss, misuse, unauthorised access, and other security threats. This means regulators can assess not only whether a business selected a vendor carefully, but also whether that vendor actively implemented appropriate security measures. The burden of protection is no longer indirect, it is built directly into the legal framework. For businesses, this creates immediate and practical implications:

  1. Third-party risk management becomes critical, not optional
  2. Contracts alone are no longer sufficient, organisations must ensure processors genuinely comply in practice

As a result, businesses must reassess vendor relationships end to end, including due diligence processes, security controls, monitoring mechanisms, and contractual safeguards, to reflect this expanded accountability and reduce regulatory and operational risk.

Mandatory Appointment of a Data Protection Officer (DPO)

One of the most operationally significant changes introduced by PDPA 2024 is the mandatory appointment of a Data Protection Officer (DPO) for both data controllers and data processors. This requirement formalises accountability and ensures that data protection is actively governed, not managed informally or reactively. The DPO plays a central role in overseeing compliance, advising the organisation on PDPA obligations, and acting as a key liaison with the Personal Data Protection Commissioner.

For businesses, this requirement signals a clear expectation that data protection oversight must be structured and empowered. Compliance can no longer be treated as a side responsibility handled on an ad-hoc or part-time basis without authority. To be effective, the DPO role must be supported with adequate resources, access to decision-makers, and operational independence. Importantly, appointing a DPO does not shift liability away from the organisation—ultimate accountability for compliance remains firmly with the business.

Mandatory Data Breach Notification: Time Is Now a Risk Factor

PDPA 2024 introduces mandatory personal data breach notification, marking a fundamental shift from the previous regime where breach reporting was not legally required. Under the new framework, once a business has reason to believe that a personal data breach has occurred, regulatory expectations move quickly from awareness to action.

Specifically:

  • The Personal Data Protection Commissioner must be notified as soon as practicable
  • If the breach causes, or is likely to cause, significant harm, affected individuals must also be notified without unnecessary delay

Failure to meet these obligations can result in:

  • Fines of up to RM250,000
  • Imprisonment of up to two years
  • Or both

For businesses, this means that delayed detection, unclear escalation paths, or untested incident response processes now translate directly into regulatory and reputational exposure. Speed, clarity, and preparedness have become critical risk factors.

Biometric Data Is Now Classified as Sensitive Personal Data

PDPA 2024 explicitly recognises biometric data—including fingerprints, facial recognition data, and behavioural identifiers as sensitive personal data. This classification reflects the heightened risks associated with biometric information, which is uniquely personal and difficult, if not impossible, to replace once compromised. As a result, businesses handling biometric data are subject to stricter requirements and closer scrutiny, particularly around:

  • Access controls and user authorisation
  • Secure storage and encryption mechanisms
  • Clear justification for collection and processing
  • Defined and limited retention periods

Organisations using biometric systems for authentication, surveillance, HR management, or customer services must reassess whether existing safeguards are proportionate to the increased sensitivity of this data.

Data Portability Rights: New Expectations from Customers

For the first time, PDPA grants individuals the right to data portability. Customers can now request that their personal data be transferred directly to another data controller, provided this is technically feasible and compatible in terms of data format. For businesses, this introduces new operational and technical expectations:

  • Data systems must support structured and interoperable formats
  • Identity verification processes must be robust and secure
  • Request handling workflows must be documented, tested, and repeatable

Organisations that fail to operationalise data portability risk more than regulatory non-compliance, they also risk eroding customer trust in an environment where switching providers is increasingly easy.

Cross-Border Data Transfers: Adequacy Over Whitelists

PDPA 2024 removes the previous whitelist-based approach to cross-border data transfers. Instead, personal data may be transferred to countries that offer adequate data protection laws or equivalent safeguards, subject to applicable exceptions. For businesses with regional or global operations, this requires a more active governance approach:

  • Assessing the data protection standards of recipient jurisdictions
  • Implementing appropriate contractual and organisational safeguards
  • Periodically reviewing transfer mechanisms as laws and risks evolve

Cross-border data governance under PDPA 2024 is no longer a static checkbox exercise, it is an ongoing compliance and risk management responsibility.

Penalties Have Increased and So Has Enforcement Risk

PDPA 2024 introduces significantly higher penalties for breaches of personal data protection obligations, signalling a tougher regulatory stance. Maximum fines can now reach RM1 million, with imprisonment of up to three years for certain offences. This represents a substantial increase from the previous framework and reflects the seriousness with which data protection is now treated under Malaysian law.

For businesses, these changes send a clear message: non-compliance is no longer a low-risk issue. Enforcement actions are expected to carry real financial, legal, and reputational consequences. Organisations that fail to strengthen governance, security controls, and incident readiness may find that data protection risks quickly escalate into broader business and trust risks.

What Business Leaders Must Do Now

PDPA 2024 makes one thing clear: data protection is no longer the sole responsibility of legal, compliance, or IT teams. It is a collective business obligation that requires leadership involvement, cross-functional coordination, and clear ownership across the organisation.

  1. Update Privacy Frameworks
    Businesses must review and update existing data privacy policies, procedures, and controls to reflect the new PDPA 2024 requirements, ensuring alignment with current data flows, technologies, and regulatory expectations.
  2. Appoint and Empower a DPO
    A qualified Data Protection Officer must be formally appointed and given the authority, resources, and access needed to oversee compliance and engage effectively with regulators and internal stakeholders.
  3. Strengthen Breach Readiness
    Organisations should establish clear, tested procedures for detecting, assessing, and reporting data breaches, so incidents can be escalated and managed quickly within regulatory timelines.
  4. Manage Third-Party and Cross-Border Risks
    Businesses need to reassess vendor relationships and international data transfers by evaluating data protection standards, contractual safeguards, and ongoing compliance of third parties.
  5. Operationalise Individual Rights
    Processes for handling data portability and other individual rights must be standardised, documented, and supported by systems that can respond accurately and securely.
  6. Embed Data Protection into Risk Management
    Data protection should be integrated into enterprise risk management frameworks, ensuring privacy risks are identified, monitored, and addressed alongside financial, operational, and cyber risks.

Ultimately, PDPA 2024 requires business leaders to treat data governance as a strategic priority, not an operational afterthought—one that directly affects trust, resilience, and long-term business sustainability.

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Conclusion

PDPA 2024 marks a timely and important step in strengthening Malaysia’s data protection framework, creating clearer expectations for businesses and positioning the country as a credible player in the global digital economy. For organisations, these amendments are more than regulatory changes—they are a readiness test. Businesses that act now by embedding governance, accountability, and security into daily operations will not only reduce compliance risk, but also strengthen trust and long-term resilience. 

In this context, platforms like SiberMate play a vital role by addressing the human side of data protection—helping organisations build strong security awareness, manage human cyber risk, and foster secure behaviour across employees. By focusing on people, culture, and continuous learning, data protection becomes an everyday habit embedded in how teams think and act, not just a policy on paper.