A registered Data Protection Officer, looked after by lawyers.
Since June 2025, appointing a DPO is a legal requirement for most sizeable organisations in Malaysia. We take on that role for you — registered, independent and answerable to your board — so your compliance is handled properly, quietly and well.
The PDPA changed in 2025. Here's what it means for you.
The Personal Data Protection (Amendment) Act 2024 came into force in three phases. It raised the penalties and set a clear standard for who must appoint a DPO. Two penalties are often confused — the difference is worth getting right.
Administrative
“Data User” becomes “Data Controller”; processors gain direct obligations.
Penalties & cross-border
Fines raised to RM1m; biometric data made sensitive; whitelist removed.
DPO & breach
Mandatory DPO; 72-hour breach notification; data portability.
DPIA & ADMP
Automated decisions trigger a mandatory DPIA — no volume exemption.
Sources: PDPA (Amendment) Act 2024; PDPD Guidelines — DPO Appointment (Feb 2025), DPO Competency (Aug 2025), DPIA/ADMP (Apr 2026). Last reviewed July 2026.
If any one of these is true, appointment is mandatory.
You don't need to meet all three — a single condition triggers the obligation. Most groups handling customer, payment, HR or health data cross at least one.
Not sure where you land? Try the quick check below — or simply ask us.
Why organisations ask us to be their DPO.
The role needs independence, current knowledge of the law and steady, continuous cover. Here's how an outsourced appointment compares with building the function internally.
| Consideration | Internal hire | ELP outsourced DPO |
|---|---|---|
| PDPA specialisation | Rare; usually a stretched generalist | A practising law firm, 15 years in PDPA |
| Independence | Hard to maintain internally | Objective; answerable to your board |
| Regulator liaison | Limited experience | Named point of contact with the Commissioner |
| Registration & filing | Your team's burden | We register and maintain the appointment |
| Continuity & cover | Single point of failure | A team, with breach-response standby |
Practical work products — not advice in the abstract.
A defined set of documents and systems a regulator, client or auditor can actually see. Every engagement builds these.
PDPA Gap Assessment
Department-level scoring across 10 control areas, with written recommendations.
Data Inventory & RoPA
A living Record of Processing Activities — the first thing a regulator asks to see.
Bilingual Policy Suite
Master handbook, notices, SOPs and DPA clauses — in English and Bahasa Malaysia.
72-Hour Breach Playbook
A detection-to-notification plan, drilled with your team until it's second nature.
DPIA / DPbD / ADMP
Risk screening for new and automated processing — cleared before it goes live.
Vendor & Cross-Border
DPA templates, due-diligence checklists and transfer safeguards for data leaving Malaysia.
Training & Awareness
A 10-module PDPA e-learning library plus live board and management sessions.
Proprietary Tools
In-house DPIA and assessment platforms — built by us, not licensed.
Not sure where you stand? Take a look.
Set your data footprint below for an indicative read on whether a DPO is mandatory and what obligations apply. It's a guide, not legal advice — but it's a useful starting point before we talk.
Your data footprint
Answer three quick questions.
Indicative guide only — not legal advice. Thresholds under the PDPA (Amendment) Act 2024. Book a consultation to confirm your exact obligations.
Two tools we built ourselves.
We didn't just read the guidelines — we built practical software around them. Both are free to start and follow the regulator's own methodology.
Prepare a DPIA in the regulator's own template
Structures your inputs into Annex A of the PDPD's DPIA Guideline (v1.0, 30 April 2026) — 35 questions, the DEICA methodology, an audit-ready draft download.
Open the DPIA Assistant →A 15-minute PDPA compliance assessment
67 questions across 10 categories produce a readiness score and a prioritised action plan. No registration to start; instant results.
Take the assessment →Six areas, one bundled function.
Delivered as a single retained appointment — scoped to your organisation's size, sectors and data footprint.
Core Scope
- Named DPO appointment
- Liaison with the Commissioner
- PDPA compliance advisory
- Frontline data-subject requests
Risk & Compliance Review
- PDPA gap assessment
- Remediation advisory
- DPIA support for high-risk work
Policy & Training
- Privacy notices & internal policies
- IT / security policy drafting
- Compliance handbook
Third-Party Compliance
- PDPA clauses for vendor contracts
- Third-party due diligence
- Cross-border transfer safeguards
Incident & Breach
- 24/7 on-call breach advisory
- Data Breach Notification (DBN)
- Recovery & post-incident review
Monitoring & Reporting
- Quarterly compliance reviews
- Internal spot checks / audits
- Annual PDPA report to the board
Meet Edwin Lee.
Protecting personal data isn't only about following the law — it's about safeguarding the trust your clients, partners and teams place in you.
Edwin has spent 15 years helping organisations of every size navigate the PDPA with confidence — from policy to practice, and from paperwork to people. He leads ELP's DPO practice and appears regularly in the media on data protection.
Edwin and the ELP team meet the KSA competency and appointment criteria in the PDPD Guidelines on the Appointment of DPOs (Feb 2025) and DPO Competency (Aug 2025). Supported by associate Wong Shen Ming (Corporate & Technology).
Already the appointed DPO for listed companies and MNCs.
ELP currently acts as Primary or Secondary Data Protection Officer across the sectors below. Client identities are anonymised for confidentiality.
ELP acts as Primary or Secondary DPO for each engagement listed.
A steady 24-month function, not a one-off project.
The Commissioner's Guideline on the Appointment of DPOs (Para 6.6) recommends a 24-month structure so capability is genuinely built and sustained. Onboarding runs in about two weeks; registration within the 21-day window.
Build
Gap assessment, RoPA, bilingual policy suite, DPO office set-up, breach protocol and DPA templates.
Active Advisory
The framework embedded in live operations — DSARs, vendor DPAs and new-process DPIAs run with our support.
Steady-State
Supervisory advisory, periodic re-assessment, regulatory-update briefings and breach-response standby.
Running throughout: quarterly reviews · annual board report · 24/7 breach line · named Commissioner liaison
Frequently asked questions
Let's find out where you stand.
Book a consultation to confirm your DPO obligation, review your breach-response readiness, or scope an engagement. No pressure — just a clear, practical conversation.