PDPA 2010 section 39(d): disclosure on a reasonable belief that the data subject would have consented (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 39(d) and (e))

A controller may disclose for a new purpose if it reasonably believed the data subject would have consented had they known of the disclosure and its circumstances. The Commissioner has published nothing saying that a paid AI licence qualifies, so relying on it for a commercial licence is a risk, not a safe route.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

In the source's own words

“(d) the data controller acted in the reasonable belief that he would have had the consent of the data subject if the data subject had known of the disclosing of the personal data and the circumstances of such disclosure; or (e) the disclosure was justified as being in the public interest in circumstances as determined by the Minister.”

Where it was read

PDPA 2010 section 39(d): disclosure on a reasonable belief that the data subject would have consented, Malaysia, checked 18 Oct 2026
Everything read from this source (6)