Thailand Issues New Rules On Data Subject Access Requests

On July 16, 2026, Thailand’s Personal Data Protection Committee (PDPC) published a notification in the Government Gazette establishing detailed rules governing data subjects’ right of access under section 30 of the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The notification will take effect 60 days after publication—mid-September 2026—giving data controllers a limited window to bring their processes into compliance.

Scope

The notification covers requests to access or obtain copies of personal data and requests for disclosure of the source of data collected without consent. Data subjects may exercise their rights directly or through authorized representatives.

Key Requirements

Important requirements set by the notification include the following:

• Required request channels. Controllers must provide at least two request channels: direct submission at the business location and registered mail. Electronic channels are optional but, if offered, may also be used for fulfilling requests.
• Request contents. Requests must be in writing or in electronic form and include the data subject’s name, the preferred access method, details of the data requested, and the requester’s signature. Controllers may request additional identifying information as needed.
• Identity and authority verification. Controllers may require official identity documents for verification. Authorized representatives must provide authorization documents and identity documents for both the data subject and the representative. Alternative verification methods (e.g., digital authentication) are permitted if they do not unreasonably obstruct data subjects’ rights.
• Review and response timelines. Controllers must review requests within 15 days. If the request is incomplete, the controller must notify the requester and allow at least 15 days to correct deficiencies. If not corrected, the request may be treated as abandoned. Once verified, controllers must fulfill requests within 30 days, extendable by another 30 days for large-volume or complex requests with notice to the requester.
• Methods for providing access or copies. Controllers may fulfill requests by allowing inspection, providing document copies, or granting electronic access. If a request is submitted electronically, the response should also be electronic where possible.
• Grounds for refusal or limitation. Controllers may refuse requests where permitted by law or court order, where compliance would harm third-party rights (including personal data, trade secrets, or IP), or where the request is manifestly unfounded or unreasonably burdensome. Controllers must provide data subjects with the reason for refusal in writing, and the refusal must be recorded in the controller’s records.
• Allowable fees. Electronic access without special recording or delivery costs should generally be free. Where fees are permitted, they must be reasonable, not exceed actual costs, and comply with the schedule attached to the notification. Fee details must be disclosed to data subjects in advance of any requests.
• Recordkeeping. Controllers must retain records of requests and responses for at least two years. Electronic recordkeeping is permitted.
• Interaction with other laws. Where other laws impose access-related duties, controllers must comply with those laws while remaining consistent with this notification’s procedures.

Next Steps

Data controllers being subject to the PDPA, both onshore and offshore, should assess their current data access request handling procedures against the notification’s requirements, including whether they offer the mandatory request channels and can meet the prescribed timelines. Key actions include:

• Conducting a gap analysis of existing procedures against the new requirements.
• Updating privacy notices and internal policies to clearly communicate request channels, fee schedules, and processing timelines.
• Implementing or updating request management systems to track requests, verification status, deadlines, and record retention.
• Training relevant personnel, particularly data protection officers, customer service teams, and legal and compliance staff, on the new timelines and procedures.
• Preparing template responses, including refusal notices with documented reasons, correction requests, and abandonment notifications.

Given the short compliance window, organizations that have not yet established formal data access request procedures should begin implementation promptly.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.