AI GUIDE FOR BOARDS IN SINGAPORE
Section V: Organisational Resilience and Capability
11.3.3 Data residency
11.3.4 Data lineage
AI systems frequently rely on cloud infrastructure, regional data pools and third- party AI providers that may operate across multiple jurisdictions. Boards should ensure management understands where sensitive data resides, where it is processed, how cross-border transfers occur, and what regulatory obligations apply. For Singapore companies, relevant obligations may arise under Singapore’s Personal Data Protection Act, the EU’s General Data Protection Regulation, and sector-speci c requirements such as those issued by the Monetary Authority of Singapore. Boards should ensure that cross-border data ows comply with approved transfer mechanisms, appropriate contractual safeguards and e ective oversight of third-party providers.
Boards should expect organisations to maintain visibility into where data originated, how it has been transformed, who has access, and how it has been used by AI systems. Strong lineage and auditability support regulatory compliance, explainability, bias detection, incident investigation and operational assurance.
Boards should recognise that explainable AI outcomes depend on the quality and traceability of the underlying data foundation.
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