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Singapore: Personal Data Protection Commission clarifies use of National Registration Identity Card numbers

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In brief

In December 2024, privacy concerns were raised after the new Bizfile portal of the Accounting, Corporate and Regulatory Authority of Singapore displayed names and full National Registration Identity Card (NRIC) numbers for free in its search results.

The Personal Data Protection Commission (PDPC) has since clarified the appropriate use and misuse of NRIC numbers.

In more detail

The PDPC emphasised that NRIC numbers should not be used as passwords. The PDPC also highlighted that organisations must avoid using NRICs for authentication purposes, and that it has consistently taken organisations to task for using NRIC numbers for authentication. Organisations should not use NRIC numbers as user names or unique identifiers in their applications, websites or public-facing systems.

The PDPC also clarified that NRIC numbers should not be used as default passwords for services provided to individuals and warned organisations with such practices to phase them out as soon as possible. Instead, authentication practices for administrative accounts should be designed with strong requirements, such as complex passwords or multi-factor authentication.

Further, the PDPC stressed that NRIC numbers are still subject to data protection obligations under the Personal Data Protection Act (PDPA). As such, organisations must still obtain valid consent from individuals where required and comply with reasonable use of NRIC numbers in accordance with such obligations.

Key takeaways

While the PDPC continues to update its Advisory Guidelines on the PDPA for NRIC and Other National Identification Numbers, the PDPC’s recent statement on the use of NRIC numbers provides timely clarification on how such personal data should be treated and protected by organisations.

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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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Andy Leck is the head of the Intellectual Property and Technology (IPTech) 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 also leads the Myanmar IP Practice Group. Andy is recognised by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal 2018. In addition, Chambers Asia Pacific notes that Andy is "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear disputes at IPOS for a two-year term from April 2021. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center. He is also appointed as a Notary Public & Commissioner for Oaths in Singapore. He previously served on the International Trademark Association’s Board of Directors and was a member of the executive committee.

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Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He 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. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

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Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is regularly ranked as a leading TMT and competition lawyer by top legal directories, including Chambers Asia Pacific and Legal 500 Asia Pacific. Ken 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.

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Sanil is a local principal in the Intellectual Property & Technology Practice Group in Baker McKenzie Wong & Leow. Sanil is qualified in both Singapore and Australia, and is a Certified Information Privacy Professional (CIPP/A) by the International Association of Privacy Professionals. Sanil is recognized as a Rising Star by both Legal 500 Asia Pacific in the Intellectual Property: Local Firms category as well as by IP Stars for his advisory work in the IP space. Sanil is also recommended by World Trademark Review 1000 for IP enforcement, litigation, prosecution and strategy.

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Daryl Seetoh is a local principal in the Intellectual Property & Technology (IPTech) practice group at Baker McKenzie Wong & Leow. He is a qualified lawyer in Singapore, and is a member of the International Association of Privacy Professionals (IAPP) as a Certified Information Privacy Professional for Asia (CIPP/Asia), an IAPP Certified Information Privacy Manager (CIPM) and a Certified Information Privacy Professional for Europe (CIPP/E). Daryl has previously worked at Baker McKenzie’s San Francisco office and has also been seconded to financial institution and technology multinational clients.

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