Security Requirements and Breach Notification
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Security Requirements and Breach Notification Start Comparison
Do data privacy laws or regulations impose obligations to maintain information security controls to protect personal data from unauthorized access or processing?

Last review date: 2 January 2025

Yes.

☒  general obligation to take appropriate / reasonable technical, physical and/or organizational security measures

☒  obligation to take specific security measures e.g., encryption

Do other laws or regulations impose obligations to protect systems from cyberattack?

Last review date: 2 January 2025

Yes.

☒  network information security requirements (broader than telecommunications)

☒  health regulatory requirements

☒  financial services requirements

☒  telecommunication requirements

☒  providers of critical infrastructure

☒  other

If yes, please provide brief details of the relevant law or regulation.

Cyber information security laws stipulate several requirements for the protection of cyber information security for both critical and non-critical information systems. Enterprises providing services in cyberspace in Vietnam are also responsible for implementing different cybersecurity measures such as alerting cybersecurity risk, developing an incident response plan, implementing appropriate response measures in light of an actual incident, reporting, and cooperation. Banking regulations also prescribe protection measures in relation to information safety and cybersecurity. Law 2023 on Telecommunications also requires compliance with cybersecurity laws when rendering telecom services. Law 2023 on Medical Examination and Treatment also makes general reference to the obligation to apply security measures in medical establishments, which can be broadly interpreted to necessitate the adoption of cybersecurity measures to protect patients' health-related information. Information safety and security, which can potentially be infringed by a cybersecurity incident, are also regulated under other domains of laws such as consumer protection, e-commerce, information technology, etc.

Has there been regulatory activity – including enforcement action, investigations, regulatory guidance or other public statements by the regulator – relating to cybersecurity by the following regulators in the last 12 months?

☒  Data privacy

☒  network information security

Does data privacy or cybersecurity law impose obligations to make notifications about personal data security breaches?

Last review date: 2 January 2025

Yes.

Data breach is currently regulated under different general and sector-specific regulations. Data breach can be either a personal data violation under the PDPD, a cybersecurity incident or cyber information security incident respectively per cybersecurity or cyber information security laws, or an attack on the information system that poses a risk to the consumer information's security and safety pursuant to consumer protection regulations, etc. The reporting entity, deadline, and procedure also vary across pieces of legislation and regulations.

Controllers/Owners have to notify:

Last review date: 2 January 2025

☒  data protection authorities

The data protection authorities to whom a report must be submitted vary across sectors and are determined by the specific legal documents that grant them jurisdiction.

  affected individuals

Article 41.1.c of the LOCS generally requires enterprises providing services in cyberspace in Vietnam to notify users of information breaches or risks of such breaches. However, the LOCS and its implementing Decree (i.e., Decree No. 53) do not provide details on the timeline and method of notification to users, and as a result, this requirement has not been actively enforced.

Furthermore, a controller may need to notify impacted data subjects of a personal data breach to ensure their right to know under the PDPD.

  other

Cyber information security laws further require an incident report to be made to members of the incident response network.

Processors/Agents have to notify:

Last review date: 2 January 2025

  controller

Under the PDPD, a processor has to notify its controller as soon as possible upon being aware of a personal data violation. An information system operator under cyber information security laws is tasked with reporting an incident to its administrator within five days after detecting the incident.

  data protection authorities

Where the laws do not differentiate between a processor and controller, the entity responsible for data processing (which can be a processor under the PDPD) must notify a data breach to competent data protection authorities.

  affected individuals

Article 41.1.c of the LOCS generally requires enterprises providing services in cyberspace in Vietnam to notify users of information breaches or risks of such breaches. However, the LOCS and its implementing Decree (i.e., Decree No. 53) do not provide details on the timeline and method of notification to users, and as a result, this requirement has not been actively enforced.

  others

Cyber information security laws further require an incident report to be made to members of the incident response network.

Are there any additional sector-specific or non-personal data security breach notification requirements?

Last review date: 2 January 2025

Yes.

☒  other

In the context of e-commerce websites, when an information system is hacked and there is a risk of loss of consumer information, the organization storing such information must notify the authorities within 24 hours after detecting the breach.

In the context of banking, credit institutions (with the exception of people's credit funds and microcredit institutions), branches of foreign banks and intermediary payment service providers must report cybersecurity incidents to the State Bank of Vietnam (via email: antt@sbv.gov.vn) within 24 hours of the incident being detected and within five working days after the completion of the incident resolution.

In the context of consumer protection, traders are obliged to notify a competent authority within 24 hours after the detection of an attack on the information system that poses a risk to the security and safety of consumer information.

In the context of cyber information security, operators of information systems must notify an incident to various incident response agencies within five days after detecting a non-serious cyber information security incident (e.g., incidents not involving State secrets).

In the context of cybersecurity, enterprises providing services in cyberspace in Vietnam are required to notify users and report to the specialized cybersecurity force in the event of an actual or potential leak or loss of user data.