Can service providers deny access if data use is not consented?

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Service Providers Cannot Deny Access Solely Based on Non-Consent for AI Training Data Use

Organisations such as banks, insurers, and social media platforms are prohibited from refusing to provide services to consumers if these consumers do not agree to their personal data being used for training artificial intelligence (AI) systems. This stipulation ensures that essential services remain accessible, irrespective of consent for AI-related data utilisation.
New Guidelines Mandate AI Data Use Notifications

From July 20, organisations in Singapore are required to inform users about the use of their personal data for the development or improvement of generative AI models. These notifications, which can be delivered via in-app pop-ups or webpages, aim to enhance transparency regarding the types of personal data being handled, including names, contact details, photographs, and financial records. The guidelines were introduced by the Personal Data Protection Commission (PDPC) to address accountability as more entities engage with generative AI.
Opt-Out Options Not Universally Required

While transparency regarding data use for AI training is being mandated, the new guidelines do not compel companies to provide a standard format for these notices or make it obligatory for consumers to have an opt-out or withdrawal of consent mechanism. This means that consumers will be informed about the use of their data but may not always have the ability to prevent it.
Anonymised Data Exemption from Notification

Companies are not required to issue notifications when they utilise anonymised data that cannot be linked back to any identifiable individual. This exception allows for the continued use of data for AI development without the administrative burden of individualised notices, provided the data is effectively de-identified.
Voluntary Chatbot Information Cards Encouraged

Beyond the mandatory notifications for AI training data, Singapore has also introduced voluntary guidelines for AI chatbot providers. These encourage clearer communication to users about the capabilities, limitations, reliability, and safety measures of their systems. The recommendation includes providing a "chatbot information card," akin to a medicine label, detailing the AI tool's purpose, suitability, data handling practices, and reporting procedures for issues.

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Can service providers deny access if data use is not consented?

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