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Data Localization and Privacy Compliance

A Report by CYS Global Remit Legal & Compliance Office


Part 4: Data Localization and Privacy Compliance

Data protection laws are increasingly shaping the compliance landscape for payment institutions operating across borders. Jurisdictions like the EU (GDPR), China, India, and Canada impose strict rules on cross-border data transfers, creating a complex regulatory environment that demands careful navigation.


Diverse Regulatory Requirements Across Key Jurisdictions

Understanding the specific requirements of each jurisdiction is critical for payment institutions seeking to operate globally:


GDPR (European Union)

  • Requires explicit consent and robust safeguards for data exported outside the EU

China's Cybersecurity Law

  • Mandates local storage of payment data within Chinese borders

India's Personal Data Protection Bill

  • Restricts outbound data flows, particularly for sensitive personal information


Singapore's payment institutions must reconcile these requirements with their own data handling practices. This includes ensuring secure storage, encryption, and access controls, whilst maintaining transparency with users about how their data is collected, used, and transferred.


Key Takeaway

Institutions must invest in data governance frameworks that align with global privacy standards. This includes conducting data impact assessments, implementing secure cloud solutions, and ensuring compliance with MAS's Technology Risk Management Guidelines.


Payment institutions that proactively build flexible, robust data governance frameworks will be better positioned to adapt to evolving regulatory requirements whilst maintaining customer trust and operational efficiency in the global marketplace.

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