hello@sterling-grc.com +1 201 263 4443 New York ISO & GRC consulting in 60+ countries
SterlingInternational Consulting Talk to a consultantTalk to us

PIPA · South Korea personal information protection law

South Korea PIPA compliance and requirements, so your data handling holds up when someone asks.

Turn South Korea's Personal Information Protection Act into routines your people follow and records you can show: lawful processing, clear notices, a named privacy officer, supervised suppliers, breach reporting and safe transfers abroad. Sterling's expert and experienced consultants map where personal information flows, close the gaps with your team and keep the evidence current, working alongside your legal advisers, in 60+ countries. We help our clients put it into practice and prove it.

  • One proposal: consulting, Effivity software, Sterling Academy access and internal auditor training, as applicable to your standard
  • A team of expert and experienced privacy consultants, putting data protection programmes in place across sectors and countries since 2003
  • The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements. No certificate exists for the Act and Sterling does not certify; the Personal Information Protection Commission (PIPC) is the regulator

8,100+ client engagements in 60+ countries.

Privacy client experience
  • Allianz
  • Emirates Flight Catering
  • Etihad Rail
  • Haier
  • Whirlpool
  • Emerson
  • Olam
  • Piramal Pharma Solutions

What it is

What is South Korea's Personal Information Protection Act and what is it used for?

The Personal Information Protection Act (PIPA) is South Korea's general law on personal information. It ties lawful processing, safeguards, privacy policies, privacy officers, supplier contracts, breach reporting and transfers abroad into one regime, and it gives people rights over their data, including access, transmission and objecting to fully automated decisions that significantly affect them.

The Personal Information Protection Commission (PIPC) supervises the Act. Compliance is shown by records, notices, contracts and controls rather than by a mandatory certificate. For a business the practical test is simple: for any personal information you hold, could you explain on what basis you collected it, who processes it for you, how it is protected and where it goes? A working programme makes that answer quick and documented.

Current law. The Commission states that the amended Personal Information Protection Act and its Enforcement Decree took effect on 15 September 2023. Notices, policies and supplier contracts drafted before then are the first things worth checking. Confirm current wording and any sector rules with the Commission's guidance and your legal advisers.

Who it is for

Who needs to comply with PIPA?

The Act applies to organisations that process personal information in South Korea, whatever their size, including employers holding staff records, and it reaches overseas companies that serve users there. Organisations usually come to Sterling for a structured programme from one of four directions:

  • A customer's due diligence asks how you protect their data. Korean and international buyers send privacy questionnaires and expect a privacy policy, a privacy officer and a breach process you can describe on request.
  • You process data for others, or others process it for you. Entrusted processing must be governed by a document, and the business that entrusts it educates and supervises the supplier, so cloud, SaaS and outsourcing providers are asked for evidence.
  • An overseas company serves users in Korea. A controller with no address or place of business in Korea that meets the criteria set by Presidential Decree designates a domestic agent in writing, and its notices and transfers must still meet the Act.
  • Automated decisions or AI use personal information. People can object to fully automated decisions with a significant effect on them and ask for an explanation, so HR, credit, marketing and AI teams need a routine for it.

The aim is handling of personal information that you control and can evidence. Compliance depends on how the rules are applied every day, not on a policy document alone.

Requirements

What are the main PIPA requirements?

Strip away the vocabulary and South Korea's Personal Information Protection Act requires a business to comply in six areas. The list below puts each one in business terms; the Act and the regulator's guidance give the full wording and exceptions.

  • Collection has a lawful basis: personal information is collected and used only on a recognised basis, for stated purposes, and no further than those purposes need.
  • People are informed and can act: individuals are told how their data is used and can exercise their rights, including access, transmission and objecting to fully automated decisions.
  • Accountability is named: a privacy policy is published, a privacy officer is appointed, and foreign controllers meeting the criteria appoint a domestic agent.
  • Suppliers are supervised: where processing is entrusted, a document governs it and the business educates and supervises the supplier.
  • Data is secured and breaches reported: safeguards include an internal management plan and access records; affected people are notified without delay and the regulator is told.
  • Transfers abroad rest on a basis: personal information goes overseas only on a recognised basis, such as separate consent, a statute or treaty, or a destination the regulator accepts.

What does useful PIPA evidence look like?

An inventory of the personal information you hold and the basis for each use, privacy notices and the published privacy policy, the privacy officer's designation, supplier documents for entrusted processing and records of their supervision, the internal management plan and access records behind your safeguards, a breach register with notification decisions, and the basis recorded for each transfer abroad. We build these records into Effivity so they stay current rather than being assembled after a complaint.

Compliance route

How do you achieve PIPA compliance?

There is no certificate at the end of this route. Compliance is something your organisation demonstrates, to the Personal Information Protection Commission if a complaint or incident arises, and to customers who ask. Sterling helps you build and run the programme; interpretation of the law in contested cases remains with your legal advisers and, ultimately, the regulator and the courts.

  1. 01
    Map the personal information you handle.Customers, staff, suppliers and any other individuals: what is collected, on which basis, where it is stored, who processes it for you and whether it leaves Korea.
  2. 02
    Gap analysis: compare current practice with the Act.Each area of the Act reviewed against what actually happens, with actions, owners and dates agreed.
  3. 03
    Put the controls and routines in place.Designate and brief the privacy officer, publish the privacy policy, update notices and consents, put supplier documents in place, tighten safeguards and access records, and agree a breach response procedure.
  4. 04
    Test the programme and review the results.Internal review of samples, a simulated incident or data-subject request, and a management review that closes findings with evidence.
  5. 05
    Operate, demonstrate and keep it current.Answer requests on time, record incidents, supervise suppliers, refresh training and revisit the inventory when systems, suppliers or the law change.

Check the route before you sign. No one can issue a certificate of compliance with PIPA itself. If a customer wants independent assurance, the Commission may certify personal information protection, ISMS-P is the integrated certification operated with KISA, and ISO/IEC 27701 is certifiable by an accredited certification body; confirm any body's accreditation directly with the accreditation body concerned.

Cost

How much does PIPA compliance cost?

The cost of a PIPA programme is driven by how much personal information you hold, how many systems and suppliers touch it, and how much already works. Your proposal shows each component, with what is included and what remains for your legal advisers.

Cost componentWhat affects it
Consulting and implementationVolume and sensitivity of personal information, number of systems, entities, suppliers and transfers abroad, and whether you choose Design™ or Drive™
Legal reviewAny advice you take from your own legal advisers on contested interpretations or contract wording, arranged separately
Internal resourcesTime from the privacy officer, system owners and managers, plus any security or process changes the gap analysis identifies
Software and learningIncluded in a Sterling engagement: Effivity for registers and evidence and Sterling Academy access for your people, confirmed in the proposal
Continued supportPeriodic reviews, refresher training, incident exercises and updates when the law or your systems change, under Sustain™

What changes the scope

  • How many groups of individuals and data sources are involved
  • Suppliers handling entrusted processing, cloud services and transfers abroad
  • Whether a domestic agent or ISMS-P preparation is part of the scope
  • Whether another programme, such as GDPR or ISO/IEC 27701, already exists
  • Deadlines set by a customer, contract or incident

What every Sterling proposal states

  • Deliverables, assumptions, exclusions and who does what
  • What remains for your legal advisers, stated plainly
  • Effivity, training and Academy access itemised at no additional cost
  • Payments linked to delivered milestones
  • Every component shown, so nothing is added later

Timeline

How long does PIPA compliance take?

Timing depends on how scattered your personal information is, how quickly system owners respond and how much has to change. Your proposal sets out the phases for your scope, long enough to map the information, fix the gaps and show that requests and incidents are handled the way the procedures say.

PhaseWhat sets the pace
Mapping and gap analysisAccess to system owners, supplier contracts and existing notices and policies
ImplementationNotice rewrites, supplier contract updates, security changes and approvals
Testing and reviewTime for requests and incidents to run through the new routines, then internal review and management review
Ongoing operationRefresher training, supplier changes and new guidance from the Commission

If a customer or contract has set a date, tell us at the outset and we will say plainly what can be in place by then and what should follow.

Your engagement

What your PIPA engagement includes

Your scope covers the full programme, from the information map to evidence that runs. Sterling does not certify, attest or validate compliance with the Act, and no certificate exists for it; the Personal Information Protection Commission supervises it, and we work alongside your legal advisers.

  • Information map, gap analysis and plan

    Sources, systems, suppliers and overseas flows, with actions and owners agreed.

  • Policies, notices and procedures

    Privacy policy, notices and consents, supplier documents, request, safeguard and breach procedures, drafted from Sterling's own templates with your teams.

  • Effivity ISO & GRC software

    Registers, requests and incidents managed in Effivity, included with the engagement at no additional cost.

  • Training for everyone

    Internal auditor training for your review team, as applicable to your standard, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

  • Internal review and management review

    Sample testing, an incident exercise and findings closed with evidence.

  • Privacy officer support

    Guidance for the designated privacy officer on requests, complaints, supplier oversight and breach decisions.

Sterling OS™ sets how we deliver. Design™ is guided support, where your team builds the programme with our consultants' direction; Drive™ is managed support, where our consultants do most of the work with your input. You choose one of the two, not both in sequence. Once the programme is operating, Sustain™ keeps reviews, training and updates on schedule, and Automate™ is Effivity, where the records live.

Compliance with the Act is supervised by the Personal Information Protection Commission.

How Sterling implements ISO and GRC standards

Effivity · privacy programme software, included in every engagement

How Effivity helps you fulfil, automate and simplify the requirements of PIPA.

Every Sterling PIPA engagement includes Effivity, the ISO and GRC automation platform built by the Sterling group and used in 50+ countries. Your consultant sets up the workspace within the agreed scope, so the information inventory, notices, policies, requests, incidents, supplier reviews, training records and management reviews sit together and stay current as the business changes. Sterling consulting clients get their Effivity subscription included with the engagement, at no additional cost.

Effivity: Context of the Organisation dashboard with issues, interested parties and scope
Effivity QMS · Context of the Organisation dashboard
Lawful basis

Personal information inventory

Each category of personal information recorded with its purpose, basis, system and owner, so questions about why you hold something are answered from one register.

Notices and policy

Notices, consents and the privacy policy

Versions controlled and linked to the collection points they cover, so the published policy matches what actually happens.

Data-subject rights

Individual requests

Access, transmission, correction and objection requests logged on receipt, assigned, answered and closed with dates.

Accountability

Privacy officer and roles

The privacy officer's designation, responsibilities and decisions recorded, with management reviews on schedule.

Entrusted processing

Suppliers

Suppliers listed with the document that governs each one and the education and supervision carried out.

Safeguards

Risks and security measures

The internal management plan, access records and security risks with owners, treatments and review dates.

Breach reporting

Incidents and notifications

Incidents recorded with containment, the notification decisions taken and corrective action, in one trail.

Transfers abroad

Overseas transfers

Each transfer listed with the basis it rests on and the information given to the people concerned.

What this means when someone asks

When a customer's due diligence team, a data subject or the Personal Information Protection Commission asks how you handled something, the answer is a record: the request and its response date, the incident and the decisions taken, the notice that applied. Sustain™ runs in the same workspace, so the programme keeps producing that evidence year after year.

In your engagement

  • Subscription included with the engagement, at no additional cost
  • Configured by your Sterling consultant within the agreed scope
  • Existing registers and policies migrated, not retyped
  • Admin and user training for your team
  • Modules for EMS, OHSMS, ISMS, FSMS and more when you integrate other standards

Sterling Academy · privacy e-learning

Give every employee who handles personal information the training to do it well.

Most privacy incidents begin with an everyday task: an email sent to the wrong person, a file shared too widely. Sterling Academy provides e-learning with video lessons, practice checkpoints, a final exam and a numbered Certificate of Completion for each learner, verifiable online. Sterling consulting clients benefit from preferential course access and special pricing through their Sterling consultant, including complimentary awareness training for their people as part of the engagement.

  • Awareness for staff who collect, use or share personal information
  • Deeper learning for the privacy officer and system owners
  • Internal auditor training for your review team, as applicable to your standard, as part of the engagement
  • Completion records by team, ready for a customer's due diligence
  • New starters trained when they join

Where we work

Where Sterling delivers PIPA (South Korea)

Why Sterling

Want successful PIPA compliance? Come to Sterling.

Many Korean organisations also answer to GDPR customers, Japanese or US group companies, or ISO/IEC 27001 auditors. Sterling builds one set of privacy routines that meets PIPA and connects to those other obligations, so your people follow one way of working rather than several.

Privacy programmes in 60+ countries since 2003

Data protection work across many jurisdictions, with offices in 21 countries and one engagement team accountable for your programme.

All-inclusive proposal

Consulting, Effivity, training and Academy access in one proposal, with legal review identified separately. No surprises, ever.

Routines, not paperwork

Notices, procedures and records designed around how your teams already work, so the principles are applied at the point of collection and use.

Expert and experienced consultants

Consultants who have built privacy and information security programmes across sectors and countries since 2003, and who work alongside your legal advisers.

Sterling vs the rest: the full comparisonExplore privacy client experience

The Sterling Promise

What our PIPA compliance success guarantee means

100%on-time completion · success · 8,100+ client engagements

We stay with you until your agreed PIPA programme outcome is achieved, supporting implementation, testing and the closure of review findings. Clear explanations, practical delivery, included software and employee learning turn the investment into lasting capability rather than a policy on a shelf.

The engagement identifies the law, scope, outcome and responsibilities. Your organisation supplies accurate information and puts the agreed controls into use. No certificate exists for the Act; the Personal Information Protection Commission supervises compliance. Our commitment concerns the agreed programme support, not legal advice or a promise that no complaint or incident will ever arise.

FAQs

Frequently asked questions about PIPA

Is there a PIPA certificate in South Korea?

The Act requires none, and compliance is shown through your records, notices, contracts and controls. The Commission may certify personal information protection, and ISMS-P is the integrated certification operated with KISA; ISO/IEC 27701 certification by an accredited body is another external benchmark. Each supports customer assurance but none replaces meeting the Act.

Does a foreign company need a domestic agent under PIPA?

Sometimes. A controller with no address or place of business in Korea must designate a domestic agent in writing if it meets criteria set by Presidential Decree. The agent covers privacy officer tasks, breach notification and reporting, and document submissions. Korean counsel can check the current decree against your numbers.

When can personal data be transferred out of Korea?

Only on a ground the Act lists, such as separate consent, a statute or treaty, contractual necessity with the required notice, a recipient holding a certification the Commission recognises, or a destination the Commission finds substantially equal in protection. Your counsel should confirm which ground fits each flow.

Is ISMS-P mandatory under PIPA?

Not under PIPA, which only says the Commission may certify personal information protection, so ISMS-P is a voluntary route under that Act. Separately, the Network Act makes the national ISMS certification compulsory for listed entities, so check whether your business falls under that list.

Does our GDPR programme cover PIPA?

Partly. Data inventories, security controls and request handling carry across, and the European Commission has recognised the Republic of Korea under the GDPR. PIPA still has its own notices, privacy officer and domestic agent duties, supplier rules and transfer grounds. A gap analysis shows what to add rather than rebuilding.

Talk to a consultant

Plan your PIPA compliance programme with confidence.

Tell us your goals, locations and target date. We’ll help you define the scope, timeline and next steps.

hello@sterling-grc.com

+1 201 263 4443 (global headquarters) · your nearest office and its number are at the top of this page

What would you like to achieve?

Choose a starting point. The enquiry form takes about a minute.

Your goal
Book my free discovery call

Continue to the enquiry form to share your details. Please do not include passwords, sensitive personal information or confidential files. A Sterling consultant replies within one working day. Privacy notice