Singapore has one of the more detailed frameworks in the region for commercial messages. Teams sometimes talk about it as one rule. It is more useful to treat it as three, each answering a different question about the same campaign.
This is general information, not legal advice. Laws and official guidance change. Check the current position, and take advice on your own circumstances, before acting.
Three rules, three questions
| Rule | The question it asks |
|---|---|
| Personal Data Protection Act 2012: data protection provisions | May you collect, use and disclose this personal data for this purpose? |
| Personal Data Protection Act 2012: Do Not Call provisions | May you send this marketing message to this Singapore telephone number? |
| Spam Control Act 2007 | Does this unsolicited commercial message, sent in bulk, meet the Act’s requirements? |
The PDPA is administered by the Personal Data Protection Commission (PDPC). A campaign can be fine under one rule and still need attention under another, so it helps to check each one separately.
Business contact information
The PDPA’s data protection provisions do not generally apply to business contact information: an individual’s name, position or title, business telephone number, business address and business email, where that information is provided for business rather than personal purposes. This is why business-to-business email in Singapore is usually discussed differently from consumer marketing.
Two cautions. First, the exclusion concerns the data protection provisions. It does not switch off the Do Not Call provisions or the Spam Control Act. Second, it depends on the purpose for which the information was provided. A company’s published enquiry inbox is the clearest case; a personal mobile number found on a listing is not.
The Do Not Call Registry
The Do Not Call provisions concern marketing messages sent to Singapore telephone numbers, such as voice calls, text messages and faxes. Before sending such a message, an organisation is generally expected to check the number against the Do Not Call Registry, unless it has the person’s clear consent or an exclusion applies. The PDPC’s guidance describes the exclusions, including for certain business-to-business messages. Read the guidance itself before relying on one.
For outreach that is email only, the Registry is not the governing rule. It becomes relevant as soon as a campaign adds calls, text messages or messages to a mobile number.
The Spam Control Act
The Spam Control Act 2007 applies to unsolicited commercial electronic messages sent in bulk, and the Act sets numerical thresholds for what counts as bulk. Since February 2021 it has also covered bulk commercial messages sent to instant-messaging accounts. Where it applies, its requirements include:
- an unsubscribe facility, with a clear statement that the recipient may use it;
- unsubscribe requests honoured within 10 business days;
- the label <ADV> at the start of the subject line;
- a subject line and header information that are not false or misleading, and a working contact address or number;
- no sending to addresses obtained through address-harvesting software or dictionary attacks.
The Act’s tests turn on whether a message is unsolicited, commercial and sent in bulk, rather than on who the recipient is. A team planning volume into Singapore should work out whether its campaign could reach the thresholds and, if so, meet every requirement, including the label.
How we apply this
Outreach Asia treats Singapore as a market where a conspicuously published business address may be emailed in a business context. Contact addresses come only from the company’s own website. Each message carries a one-click unsubscribe, and opt-outs take effect immediately rather than within the ten-business-day window. Daily sending limits apply to each client, and every first message waits 24 hours for review before it can send.
If your own plans involve higher volumes, calls or text messages to Singapore numbers, review the Spam Control Act and the Do Not Call provisions against those plans before you start.
Before you move on.
- You know which of the three rules applies to each channel you use.
- Business contact information is used for business purposes only.
- Calls and text messages to Singapore numbers are checked against the rules first.
- Your volumes have been compared with the Spam Control Act’s thresholds.
- Opt-outs are honoured well inside ten business days.
This is general information, not legal advice. Outreach Asia describes its own rules and practices here; they are not a statement that any particular campaign complies with the law.