[Column Writing] 【ESG Strategies for Business 】35th Malaysian PDPA Revision and Practical Responses for Japanese Companies— Guidelines for DPO Appointment, Disclosure Notification, and Cross-Border Data Transfer

The Malaysian edition of the Current Affairs Bulletin (published August 26, 2026) includes a contribution by Representative Mitsuru Misawa entitled "【ESG Strategies Useful for Business 】35th Malaysian PDPA Revision and Practical Responses for Japanese Companies— Guidelines for DPO Appointment, Disclosure Notification, and Cross-Border Data Transfer."

While the previous session (34th session) discussed the National Emissions Trading Policy (NCMP) and the National Emissions Trading System (ETS) initiative, this time we have shifted our perspective to the area of governance (G), and are clarifying the amendments to the Personal Information Protection Act (PDPA) and the practical responses required of Japanese companies. In particular, the phased implementation of the revised Act (Act A1727) and increased penalties, the obligation to appoint a Data Protection Officer (DPO) based on the guidelines published in February 2025, and the obligation to provide a Data Disclosure Notice (DBN) requiring notice within 72 hours; and the Cross-Border Personal Data Transfer Guidelines and Data Portability Rights issued in April 2025.

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