PDPA 2010 section 45(2)(c): processing for statistics or research is exempt from the consent and disclosure principles (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 45(2)(c))
There is a research exemption, but it applies only if the data is processed for no other purpose and the results do not identify anyone. The Act does not define research, and the Commissioner has published no statement that training a buyer's commercial model is research, so a holder should not rely on it for a licence (my reading).
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“processed for preparing statistics or carrying out research shall be exempted from the General Principle, Notice and Choice Principle, Disclosure Principle and Access Principle and other related provisions of this Act, provided that such personal data is not processed for any other purpose and that the resulting statistics or the results of the research are not made available in a form which identifies the data subject;”
Where it was read
Also read from the same source
- PDPA 2010 section 4: personal data is information about an identified or identifiable person in respect of commercial transactions (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 4 (definitions of "personal data" and "commercial transactions"))
- PDPA 2010 sections 6 and 7: consent to process, and written notice before using data for another purpose or disclosing it to a third party (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 6(1)(a) and s. 7(2)(c))
- PDPA 2010 sections 8 and 39: no disclosure for a new purpose or to an unlisted third party without consent (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 8 and s. 39)
- 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))
- PDPA 2010 section 129 (as amended 2024): transfer outside Malaysia needs a similar law, adequate protection, or a listed condition (Personal Data Protection Act 2010 [Act 709], reprint as at 15 September 2026 (Commissioner of Law Revision, Malaysia), s. 129(2), (3)(a), (3)(f) and (5), as amended by the Personal Data Protection (Amendment) Act 2024 [Act A1727], s. 12)
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide