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Recreated source · letter

Letter to Parliament

Faithful, verbatim recreation of the original letter; the author's name and contact details have been removed.

To:
Members of Parliament
From:
The complainant
Date:
26 November 2025
Subject:
Reasons for Nineteen Months of Escalation, Exhaustion of Oversight Channels, and Reporting Potential Wrongdoing by PDPC and IMDA

Six-minute video overview

For convenience, a short six-minute video summarising the entire matter is available below. Members who prefer a quick overview may watch this first before deciding whether to read the full letter.

Video link: https://youtu.be/ldJW-LeMsao

Key preliminary concern

At the outset, I wish to highlight a critical issue that shaped the entire trajectory of this case. A PDPC officer informed me that they would not investigate unless I could first prove that the CCTV footage existed. In practice, this means that if any organisation simply denies the existence of footage, PDPC will decline to investigate. Such a position effectively creates a gap where organisations can evade statutory obligations under S21 merely by asserting that data does not exist, without verification by the regulator. This structural concern is one of the core reasons the matter had to be escalated to Parliament.

Risk created by PDPC’s redefinition of personal data

PDPC’s redefinition of what constitutes personal data goes beyond its statutory remit. By narrowing the scope of personal data through interpretation rather than legislation, the effect is to change the meaning of the PDPA without parliamentary oversight. If such an interpretation stands, it would mean that significant categories of recorded data, including CCTV footage, may fall outside the PDPA entirely. This creates a risk that organisations will rely on lower-resolution recordings or limited fields of view, knowing that data which cannot be easily linked to an identity in isolation will no longer be treated as personal data. This outcome appears inconsistent with the purpose of the PDPA and may have broad implications for public safety, accountability, and data protection.

Introduction

I respectfully submit this letter to explain why I persisted for nineteen months through every available channel and why this matter is no longer about my personal case. I have accepted that my own outcome cannot be changed. I am now reporting potential procedural and regulatory failures within the Personal Data Protection Commission (PDPC) and the Infocomm Media Development Authority (IMDA) that may affect any member of the public who relies on the statutory Access Obligation under the Personal Data Protection Act (PDPA).

I am deeply grateful that my Member of Parliament submitted two appeals on my behalf. Both appeals were unfortunately ignored, despite containing clear statutory grounds. Throughout this period, my MP has been consistently supportive, but I believe this case ultimately extends beyond what any single individual can resolve without systemic review.

Several MPs are individuals I know personally, including former colleagues and supervisors, but I deliberately did not approach any personal connections. This matter is not about influence or relationships. It is about a genuine systemic concern affecting public rights and regulatory accountability. For those who know me personally, I trust that they recognise my character and that I act with integrity and fairness. I was awarded a Commendation Medal for my service with the Ministry of Health during the Covid period, and I have always taken my responsibilities seriously.

This is not a personal grievance. It is a principled attempt to highlight a structural issue that affects all Singaporeans.

Why nineteen months of persistence

1. Exhaustion of all internal channels

I complied fully with all instructions from PDPC and IMDA. I provided evidence whenever asked and addressed every shifting rationale. Throughout, I relied solely on the PDPA, which grants a clear statutory right under S21.

2. Escalation only when necessary

Escalation became necessary only when:

Each escalation occurred only because the previous level failed to address the substantive issues.

3. Avoiding Parliament until all options were exhausted

For most of these nineteen months, I deliberately avoided bringing the matter to Parliament. I trusted the regulatory system to correct its own errors. Over time, this proved not possible.

Attempts to seek oversight beyond PDPC and IMDA

1. Public Service Division (PSD)

PSD acknowledged the matter but stated they were not empowered to intervene in PDPA interpretations made by PDPC.

2. Public Service Commission (PSC)

When I approached PSC, IMDA informed them that the issues had been addressed. This representation was factually incorrect. PSC understandably relied on IMDA’s statement, leaving no remaining oversight channel outside Parliament.

Use of AI to ensure accuracy, transparency, and consistency

In the age of artificial intelligence, I created a specialised NotebookLM chatbot to analyse the case strictly based on documents. I manually downloaded and uploaded:

NotebookLM link: https://notebooklm.google.com/notebook/4e84e17b-8886-4f94-9414-a59de26bcc7f

Unlike conventional AI systems, NotebookLM cannot hallucinate in the usual manner, because it only reasons over documents that are explicitly uploaded. Every conclusion must be grounded in the evidence. NotebookLM is not perfect and may occasionally be inaccurate, but any errors can be verified against the underlying documents. I stand ready to clarify or respond to any questions that arise from its output.

The same notebook may be reviewed by Members of Parliament. By uploading the PDPA, the Advisory Guidelines, and the rulings, any Member may independently verify whether the reasoning in the decisions aligns with the Act. The notebook also serves as a useful reference tool for any Member who may not be fully familiar with the PDPA or its technical obligations. It provides clear explanations of key statutory duties, such as the Access Obligation and the requirements imposed on organisations when handling personal data. This allows both new and experienced MPs to quickly come up to speed on the regulatory context before assessing the issues raised in this case.

I encourage MPs to use this notebook to examine any explanation provided by IMDA or PDPC. It ensures that responses can be tested objectively against the statutory text and the documentary record, rather than relying on characterisations or selective summaries.

I also prepared:

These materials were sent to PDPC, but none were addressed.

Why this is no longer about my case

1. The evidence was deleted during the active request

The CCTV footage was deleted while the request was still alive. I have accepted that nothing can be done regarding my personal outcome.

Additional observation about the official pathway. It is also important to highlight an irony that illustrates the severity of the problem. The only CCTV footage I eventually obtained came from outside the PDPA framework, through a separate non-statutory route. The official PDPA pathway failed entirely. This raises a fundamental policy question. Was PDPC’s interpretation correct, or were the PDPA, the PDPC’s own Advisory Guidelines, and the Minister’s public assurances the correct reflection of the law? Parliament may wish to determine which of these conflicting positions can reasonably stand.

2. The remaining issue is systemic

The inconsistencies between the PDPA and PDPC’s reasoning affect the integrity of the Access Obligation for all members of the public.

3. Responsibility to report potential wrongdoing

Given the potential implications for public policy and statutory rights, I believe I have a duty to report these concerns once all executive channels have been exhausted.

Disclaimer and clarification

I am willing to be corrected, and I do not insist that I must be right. However, the documentary record shows unresolved inconsistencies between the PDPA and the PDPC’s decisions. I relied entirely on the PDPA and referred to the Advisory Guidelines only because they state they reflect the Act. PDPC later disowned the Guidelines by stating they are not legal advice, yet did not explain why its decisions departed from the PDPA. Because PDPC changed its reasoning multiple times and stopped replying immediately after each contradiction was demonstrated, a gap has formed in the factual and legal explanations. Without proper statutory-based clarification, I cannot be convinced that the rulings were consistent with the PDPA.

Conclusion

The nineteen-month effort was never about overturning my personal outcome but about ensuring the integrity of the PDPA and the accountability of regulators. After approaching PDPC, IMDA, Members of Parliament, PSD, and PSC, and receiving no full or consistent explanation, Parliament remains the only institution with the constitutional mandate to review these systemic issues. I stand ready to provide all underlying documents, timelines, and materials already compiled.

Respectfully submitted,
The complainant

Attachments provided for parliamentary review

The following documents were attached for reference:

These attachments show a sustained pattern of contradictions, unanswered questions, procedural failures, and potentially misleading statements provided to higher authorities.