SI-011-02 :
Data Governance, Localization
& Cross-Border Data Flow Control

Situation

Thailand’s data ecosystem is rapidly expanding across government, finance, e-commerce, healthcare, and digital platforms. However, data governance remains fragmented, with inconsistent standards for data classification, storage, processing, and cross-border transfer.

A significant portion of Thai-generated data is:

• Stored or processed in foreign jurisdictions

• Governed by external regulatory frameworks

• Integrated into global platform ecosystems beyond national oversight

This results in limited visibility and control over how data is used, monetized, and transferred across borders, especially in strategic sectors.

Shift

The global data regime is shifting from free-flowing data globalization → controlled data sovereignty frameworks.

Countries are increasingly implementing:

• Data localization requirements

• Tiered data classification systems (sensitive / critical / general)

• Cross-border data flow agreements and restrictions

• Digital trade rules tied to national interest

Data is no longer treated as a passive byproduct—but as a strategic asset with economic, political, and security implications.

Advantage

Thailand can position itself as a Trusted Data Gateway of ASEAN by balancing:

• Controlled data governance for sensitive and critical sectors

• Open data flows for trade, innovation, and digital economy growth

Key strengths include:

• Strong integration within ASEAN digital economy

• Existing legal foundations (PDPA and sectoral regulations)

• Increasing demand for trusted data environments from global partners

• Neutral geopolitical positioning enabling multi-bloc data agreements

This enables Thailand to act as both data controller and regional data exchange hub.

Additional Structural Advantage

Thailand can develop a multi-layered data governance architecture:

• Data Classification Layer → Critical / Sensitive / General data segmentation

• Data Localization Layer → Clear rules on which data must reside domestically

• Cross-Border Data Flow Layer → Bilateral / multilateral data transfer frameworks

• Data Exchange Infrastructure → Secure national and regional data exchange platforms

• Compliance & Audit Layer → Monitoring, enforcement, and certification systems

This creates a system where data flows are not blocked—but intelligently controlled.

Implication

Without a structured data governance framework:

• Thailand loses economic value from its own data generation

• Sensitive data may be exposed to foreign jurisdictional risks

• Trust deficits limit international data partnerships

• Domestic digital ecosystem remains dependent and fragmented

With strong data governance and flow control:

• Thailand captures value from data-driven industries (AI, fintech, digital services)

• Builds trust as a secure and compliant data hub in ASEAN

• Enables cross-border digital trade under controlled conditions

• Strengthens national security and regulatory sovereignty

Action Layer