Fellow speakers,

Distinguished guests,

Ladies and gentlemen,

1. I am honoured to be invited to this prestigious event at the 6^th European Data Protection Days Conference, taking place in the beautiful city of Berlin.
 

2. You have just heard Mr Giovanni Buttarelli and Ms Julie Brill’s insightful viewpoints on how Europe and the United States are making adjustments to cope with the issue of data protection in a world that is driven by technological breakthroughs.


3. I am happy to share with you Singapore’s own experience in aligning our personal data protection regime to complement the country’s transformation into a Smart Nation.  

Singapore’s Smart Nation Vision 


4. Innovation and the advent of big data analytics rely significantly on the creative collection and use of data, including personal data. In the past decade, we saw the rapid adoption of e-commerce, social media, and mobile devices and applications that utilise data to facilitate convenience in daily lives and enhance connectivity for communications and productivity.


5. It is difficult to argue against the benefits of innovation and new opportunities that such developments bring, but it is also important to ensure that the element of trust must be maintained for users and stakeholders of such technologies. How Singapore and the Personal Data Protection Commission define this issue will affect the ability and limits of innovators.    


6. Singapore today is a highly connected island state. Appreciating the true value of smart cities – particularly along the recurring themes of “Intelligence, Liveability and Sustainability” – Singapore’s Prime Minister Lee Hsien Loong had, in November 2014, announced the country’s intention to become the world’s first Smart Nation.    


7. Two crucial components drive this vision: Big Data, which provides useful insights for urban planning among others, and the Internet of Things, where everyday devices are interconnected to make business processes more efficient and quality of lives better.         
    
   Data as an Enabler 


8. When we embarked on our journey towards the building of a Smart Nation, we recognised that this entails a whole-of-government and whole-of-nation effort.A Smart Nation Platform was therefore mooted as an anchor initiative to facilitate this passage, which included rolling out an infrastructure in which public agencies can access, manage and share various types of data. Insights gained from these data would enable public agencies to better anticipate citizens’ needs, improve delivery of services, and reduce inefficiencies.    


9. To date, Singapore has successfully utilised Big Data to enhance provision of public services on numerous fronts. For instance, the Infocomm Development Authority collaborated with the Land Transport Authority, as well as bus and train operators to draw meaningful insights from data derived from the use of public transport fare cards, which are called “EZ-link cards” in Singapore.        


10. By analysing travel and density patterns of commuters taking the public buses and local Mass Rapid Transit (MRT) trains, we are able to make accurate predictive assessment of commuter demand and adapt the transport frequency or network accordingly.    


11. To illustrate this point, I would like to draw your attention to the screen, which will be playing a short clip on Singapore’s use of Big Data to improve transport efficiency.   


12. As you can see, through the use of public transport travel data, planners in the Land Transport Authority are able to have insights into the travel patterns and demands of commuters, and thereby recommend the injection of new routes or additional buses and trains when necessary to smoothen the experience of the commuters.    


13. On a similar note, data obtained on the locations of overhead pedestrian bridges, along with residential addresses of senior citizens in Singapore, are analysed to determine which districts in Singapore would require enhancements in accessibility features to improve the welfare of our senior citizens.      


14. These are some examples demonstrating how innovation and Big Data have helped advance standard and quality of living. Accessibility features and public transport services aside, data analytics relating to behaviours and preferences of individuals have become a competitive advantage that many private organisations recognise, culminating in an inevitable growth in the volume of personal data held by them. Local hospitals, for instance, are employing data science to predict health risks, so as to put in place early control precautions.   


15. A balanced approach is therefore required to ensure that Singapore remains a trusted hub for data innovation, one that spurs the use of data to support progress in technology and innovation without compromising the confidence and trust individuals have on those collecting such information.    


16. That being said, a degree of inherent risks will, however, always continue to exist.



Not Without Risks and Challenges

17. New challenges brought forth by Big Data are indeed complex. For example, even though anonymisation can offer protection to personal data by removing personally identifiable data points, advancement in data analytics capabilities have led to an escalation in re-identification risks. Anonymised data sets not appearing to have personally identifiable information, could now be combined with other sets of anonymised data in a swifter manner to re-identify personal data again.


18. Some elements of Big Data activities also stretch the traditional approach towards personal data protection. As more data are collected from various sources such as sensors and Internet of Things, there may be potential difficulties in obtaining consent, as well as in notifying, correcting, and limiting purposes for the collection. These difficulties are further compounded if the set of data is to be used for a new purpose, as it is impossible for organisations to predict all the future purposes for the use of the data at the initial point of collection.          



PDPA’s Robustness in the Big Data Era

19. The Personal Data Protection Commission is of the view that data protection and Big Data goals are not in conflict. To Singapore, both values – the use of data to support progress in technology and innovation, as well as personal data protection – are equally crucial to its Smart Nation vision. Data sharing is encouraged, and should occur in a responsible and trusted environment. Only with good data governance could trust be gained, and this in turn propels individuals to share their personal data willingly in return for a superior interconnected lifestyle.    


20. While Singapore’s Personal Data Protection Act, also known as PDPA, generally follows a consent-based approach, there are principles therein which support the concept of Big Data and the development of a Smart Nation. For one, the PDPA is non-prescriptive and centred largely on the notion of “reasonableness”. Since the concept of “reasonableness” is not rigidly defined in the PDPA, it allows organisations a certain extent of flexibility in the use of personal data under their control.    


21. The PDPA also recognises the validity of “deemed consent” in certain situations where individuals, despite not giving actual explicit consent, are deemed to have consented to the collection, use or disclosure of their personal data. Organisations can therefore rely on deemed consent for the conduct of their business activities, on the condition that the purpose for collection, use or disclosure of personal data were made known, and that it is reasonable for the individuals to provide their personal data for that purpose.    


22. Under the PDPA, there are also certain situations whereby organisations may use personal data without consent. One example would be the use of personal data for research analysis. Under the PDPA, organisations may, in meeting certain conditions, collect and use personal data for historical and statistical research purposes without obtaining consent.    


23. Besides the concepts which I have just described, the Personal Data Protection Commission is currently supporting national reviews of key data governance issues relating to the Smart Nation Platform by providing advice on personal data protection issues such as the types of personal data that should be handled, as well as how such data can be classified, and anonymised. This is to ensure that the Platform would be built on a “trust by design” philosophy, with data protection issues being considered from the infrastructure level up, and ultimately ensuring that our Smart Nation initiatives are trusted by all stakeholders.        
       

Conclusion - Our Approach

24. Increasingly, data protection authorities have to be technocrats, as the way data is being used continues to evolve with technology changes. The role of the data protection authority should be one that encompasses both protecting the rights of individuals in personal data protection, and helping to spur data-centric business interests and economic growth. In order to achieve this, we need to cultivate a data protection culture through the implementation of robust and technologically relevant data protection policies, as well as increase our outreach efforts to consumers and organisations.    


25. In saying this, we will continue to look into ways to help organisations understand the need to protect personal data and how personal data protection and the innovative use of data in today’s economy are both sides of the same coin.


26. In a setting of constant change, it is important for regulators to review the application of their data protection regime regularly to ensure its relevance. Alternatives to a consent-based approach such as one that is based on legitimate use and accountability, protecting personal data from emerging threats of misuse and abuse, and ethical concerns are some of the areas that Singapore will be looking into to sustain its position as a trusted hub for data management and processing activities.