Analyzing critical legal trends and developments across data, cyber, AI and digital regulations from around the world and beyond borders

On 12 August 2025, the Ministry of Digital Development (MDDI) launched a public consultation to invite feedback on proposed amendments to the Public Sector (Governance) Act (PSGA) to enhance the public sector’s use of data.

The public consultation closes on 2 September 2025.


In more detail

Background

Introduced in 2018, the PSGA sets out a governance framework across public bodies in Singapore to support a whole-of-government approach to the public sector’s delivery of services.

Among other purposes, the PSGA provides a legal basis for sharing data across the public sector,  which can be made for specific purposes supporting public interest. These purposes are as follows:

  1. To uphold and promote the values of Singapore’s public sector
  2. To secure economies or efficiencies for Singapore’s public sector
  3. To directly or indirectly improve the efficiency or effectiveness of policies, program management, service planning or service delivery across Singapore’s public sector agencies (whether by carrying out data analytics work or otherwise)
  4. To ensure business continuity
  5. To ensure accountable and prudent stewardship of Singapore’s public sector finances and resources
  6. To manage risks to the government’s financial position
  7. To support a whole-of-government approach to the discharge of public sector agencies’ functions

To ensure responsible data handling, the PSGA also includes criminal offenses for individual public officers. For unauthorized disclosure and improper use of information, or unauthorized re-identification of anonymized information, individual public officials may be liable on conviction to a fine of up to SGD 5,000 and/or to imprisonment for a term of up to two years.

Proposed amendments to the PSGA

Recognizing that the government has been increasingly working with external private sector partners to deliver services to Singaporeans on the public sector’s behalf, MDDI is considering amendments to the PSGA to better support service delivery by authorized external partners that work closely with public sector agencies.

The amendments will provide a clear legal basis for public sector agencies to share data with authorized external partners under the seven public interest purposes listed above. Public sector agencies will be able to authorize an external partner to receive data that is required for the services that the external partner is delivering on behalf of the public sector. However, this will only be permitted if the data sharing is authorized by the relevant Minister or delegate, and will be subject to robust safeguards similar to what public sector agencies need to satisfy.

Amendments will also be made to the PSGA to allow public agencies to use data internally with other public agencies for the same purposes supporting public interest that are set out above.

MDDI also clarified that obligations and penalties under the Personal Data Protection Act will continue to apply to these external partners.

Key takeaways

Organizations that continue to collaborate closely with public sector agencies and share the use of data should continue to monitor MDDI’s developments to ensure compliance with regulatory requirements and best practices.

MDDI’s press release and proposed amendments are available here.

Feedback may be submitted using this link until 5 pm (SGT) on 2 September 2025.

For further information and to discuss what this development might mean for you, please get in touch with your usual Baker McKenzie contact.


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Author

Andy Leck is the head of the Intellectual Property (IP) Practice Group and a member of the Dispute Resolution Practice Group in Singapore. He is a core member of Baker McKenzie's regional IP practice and leads the Myanmar IP Steering Committee.

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Ren Jun Lim represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues.

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Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is an IAPP Certified International Privacy Professional (FIP, CIPP(A), CIPT, CIPM) and a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators. His practice focuses on IT, telecommunications, intellectual property, trade and commerce, and competition law matters.

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Sanil is a local principal in the Intellectual Property & Technology Practice Group in Baker McKenzie Wong & Leow.

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Daryl Seetoh is a local principal in the Intellectual Property & Technology (IPTech) Practice Group at Baker McKenzie Wong & Leow.

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Natalie is a local principal in the Intellectual Property & Technology (IPTech) practice group in Singapore.