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PDPA programme: full worked example

AI and data governance from someone who builds the controls, not just the policies. This is a complete PDPA programme, end to end, for one invented company: Quillmarrow Supplies Pte. Ltd. (fictional), an office-supplies distributor and online store with about 80 staff, a showroom and a Malaysia fulfilment partner. It shows the gap review, the data inventory and flow map, the notices, policy and procedures, the retention schedule, the vendor and transfer checks, the breach plan and the DPO handover you would receive, in about three to four weeks.

Fictional organisation, illustrative only, not a client case study

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The situation

Quillmarrow Supplies Pte. Ltd. (fictional) is an office-supplies distributor with about 80 staff, a Singapore showroom and warehouse, a web shop for individuals and trade accounts for businesses. Malaysia orders are fulfilled by a partner in Johor. Four things made the programme urgent. An enterprise customer's supplier questionnaire asked for a privacy policy, a breach plan and a retention schedule that Quillmarrow did not have. A SharePoint folder of customer returns data was shared with "anyone with the link" for two days in September (INC-2026-07). Marketing planned a telemarketing campaign to SME owners with no Do Not Call (DNC) checks. And the Head of Operations had just been appointed Data Protection Officer (DPO) and needed a working programme to own.

The programme ran remotely over about three to four weeks: interviews with role holders, document review and system walk-throughs using descriptions and masked screenshots. No customer database was received and no client personal data was put into AI tools.

Decisions this supports
  • What personal data Quillmarrow needs, why it needs it and where it goes.
  • Which gaps need attention first and who owns the action.
  • What staff should do when someone withdraws consent, asks for access or correction, or raises a complaint.
  • What to check before appointing a vendor or transferring data overseas.
  • How the team escalates a suspected breach and records its decisions.
  • What management and the appointed DPO need to approve and maintain.

Where each decision is answered

Decision Answered in Decided by (role)
What data, why and where it goes B3 inventory and data flow map; B8 retention schedule DPO; MD confirms retention decisions
Which gaps first, and who owns them B2 gap review and action plan MD
Withdrawal, access, correction and complaints B6 consent and withdrawal; B7 access and correction; B5 policy (complaints) DPO
Vendors and overseas transfers B9 vendor checklist; B10 transfer checklist COO with the DPO
Suspected breaches B11 breach management plan MD and DPO (notification decision)
What to approve and maintain B5 policy; B16 DPO handover pack MD; DPO maintains
Everything in the pack
RefItem (read online)PDF pagesClient approverDownloads
B0PDPA programme pack: cover and decisions3Managing DirectorPDF · DOCX
B1Programme scope sheet5Chief Operating OfficerPDF · DOCX
B2Gap review and action plan8Managing DirectorXLSX · PDF · DOCX
B3Personal data inventory and data flow map12Head of Operations (DPO)XLSX · PDF · DOCX
B4Privacy notices4Head of Operations (DPO)PDF · DOCX
B5Internal data protection policy7Managing DirectorPDF · DOCX
B6Consent and withdrawal procedures4Head of Operations (DPO)PDF · DOCX
B7Access and correction procedure and log7Head of Operations (DPO)XLSX · PDF · DOCX
B8Retention schedule7Head of Operations (DPO); MD confirms decisionsXLSX · PDF · DOCX
B9Vendor and data intermediary checklist8Chief Operating OfficerXLSX · PDF · DOCX
B10Overseas transfer checklist3Head of Operations (DPO)PDF · DOCX
B11Data breach management plan9Managing DirectorPDF · DOCX
B12DNC checklist and process4Head of MarketingPDF · DOCX
B13DPIA template, with a worked example5Head of Operations (DPO)PDF · DOCX
B14Basic AI-use policy3Managing DirectorPDF · DOCX
B15Remote staff briefing: outline and speaker notes6Head of Operations (DPO)PDF · DOCX
B16DPO handover pack7Managing DirectorPDF · DOCX

Download the whole pack as a ZIP

Every file carries the label "Fictional organisation, illustrative only, not a client case study", a version, a date, the preparer and the client approver role.

How to read it
Breach facts

The breach rule used in this pack. A breach is notifiable if it is likely to cause significant harm to the people affected, or affects 500 or more people. If it is notifiable, tell the PDPC as soon as practicable and no later than 3 calendar days after assessing that it is notifiable. The assessment is recorded separately from the decision to notify. The FAQ explains the triggers and deadlines.

About this worked example

Prepared by Alex Lew (CFA, AIGP, CIPP/A, FIP). I personally review and sign off every deliverable.

The templates behind these documents are in the AI governance and PDPA toolkit: complete and available now; one organisation, internal use, 12 months of updates. DM @alewyl1 on X, pay, then the ZIP arrives by email.

This is practical compliance support, not legal advice. For legal advice, use a Singapore-qualified lawyer. You appoint your own DPO. I support them.

Want this for your business? DM @alewyl1 on X, or ask for a free intro call (coffee chat).