THAI PDPA FILES

PDPA explainer

PDPA Controller vs Processor

The difference between a data controller and a data processor under Thailand's PDPA, and why it matters when work is outsourced.


General principle

Delegating a task does not delegate accountability. The controller remains responsible for the lawfulness and scope of what the processor does.

The processing agreement should define exactly which data the processor may access for which task.

How this issue appears in this case

The institution described the service provider as a processor acting on its behalf. The documentation defining the permitted scope is not in the public archive.

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

Last updated
17 SEP 2026
Source record last reviewed
17 SEP 2026
Case status
Ongoing