PDPA explainer

PDPA and Debt Collection

Lawful basis, necessity and outsourced debt collection under Thailand's PDPA, illustrated by a documented case.

General principle

Contractual necessity, legal obligation, legitimate interest and consent are distinct bases with different conditions and different rights attached.

A basis attaches to a specific purpose and a specific set of data — not to a customer relationship in general.

The institution described contractual necessity as the basis. The complainant questioned how one contract covers data from a separate product.

This section is not a legal conclusion and does not state that any party is at fault.