Bulletin
4notify Singapore · Government Gazette
OFFICIAL · PDPC · Do Not Call Registry
Bulletin No
BUL-SG-005
Date
2026-05-27
Status
In force
Category
Privacy

PDPA, the Do Not Call Registry and consent: the permission framework for transactional and marketing delivery in Singapore

Whereas, in exercise of the powers conferred by the Personal Data Protection Act 2012 (PDPA), the Personal Data Protection Commission (PDPC) administers the consent framework and the national Do Not Call (DNC) Registry. Marketing messages to Singapore numbers require either explicit consent or 'ongoing relationship' grounds, and the DNC registers (No Voice Call / No Text Message / No Fax) must be checked before each broadcast. 4notify carries the lawful basis on every envelope and checks DNC at the API edge for every delivery.

EmailSMSWebhook
Preamble

Whereas, in exercise of the powers conferred by the Personal Data Protection Act 2012 and the related Do Not Call Provisions, the present Bulletin is hereby published concerning the management of consent for electronic delivery into Singapore.

Statutory basis
Personal Data Protection Act 2012 (PDPA)

Lawful bases for processing, data subject rights and the competence of the PDPC.

PDPA Do Not Call Provisions

Mandatory DNC check before sending specified messages to Singapore numbers.

PDPC Advisory Guidelines on the DNC Provisions

Practical guidance on the 'ongoing relationship' exception and unsubscribe handling.

Implementation
01

Per-envelope lawful basis registration

Every envelope carries one of the PDPA bases (consent, contract, legal duty, ongoing relationship); the basis is pinned at the template level and replayed in every delivery.

02

API-edge DNC check

Before each marketing delivery 4notify checks the No Text Message register (and the No Voice Call register for voice). Numbers on the register are blocked at the API edge; the DNC cache refreshes every 24 hours.

03

STOP propagation within 30 days

STOP and UNSUBSCRIBE requests propagate within 3 days through 4notify and within 30 days through the PDPA-required suppression list across all four operators and the email gateway.

04

PDPC breach notification webhook

Any envelope-level incident raises a webhook to the data controller within 1 hour, in line with the PDPA's data breach notification obligation.

Delivery envelope
json
{
  "event": "delivery.consent_envelope",
  "controller_id": "SG-CTRL-12345",
  "lawful_basis": "consent",
  "consent": {
    "record": "PDPC-2026-001234",
    "consent_date": "2025-09-14",
    "unsubscribe_link_present": true
  },
  "dnc_check": "cleared:no-text-message",
  "delivery": { "channel": "sms", "template": "promo_v2" }
}
Sample message
EmailSubject: We have updated your marketing preferences

Dear Customer, As of today your marketing permission has been revoked. You will no longer receive promotional emails, but you will continue to receive transactional notifications (order confirmations, delivery alerts). To exercise your other PDPA rights, please email: [email protected]

Compliance checklist
  • PDPC data protection officer registration current
  • Lawful basis recorded for every commercial delivery
  • DNC check enforced at the API edge with a refresh interval no longer than 24 hours
  • Breach notification webhook reachable
The 4notify difference

4notify is the only A2P provider that pins the PDPA lawful basis to every envelope, checks the DNC register at the API edge, propagates STOP within 24 hours across all four operators and exposes a one-hour PDPC breach notification webhook.

Frequently asked questions
Does the DNC apply to SMS as well as voice calls?

Yes — the DNC has three separate registers (No Voice Call, No Text Message, No Fax). The 'No Text Message' register applies to SMS and other text-message channels. 4notify checks the register that matches the channel of the envelope.

Does the 'ongoing relationship' exception remove the need for DNC?

Partly. Under the exception, an organisation may send specified messages relating to subjects similar to those of the existing relationship, without checking the DNC, but the message must still carry a clear opt-out. 4notify enforces the opt-out link at the template level even under this exception.

Published
4notify Operations Office
2026-05-27 · BUL-SG-005

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