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PDPA for your LINE followers: a one page checklist

Updated

In LINE's own privacy policy, the business that uses LINE is the data controller and LINE acts as its processor. That puts the choices about customer data on you. This checklist helps you make them, and a Thai lawyer should check it for your case.

Written for: You collect names, phone numbers and chat history from customers on LINE, and nobody has told you what you are supposed to do with it.

What LINE says about roles

LINE Thailand's privacy policy, section 1.8, says that where LINE collects personal data for its business customers, the customers are considered data controllers and LINE is merely their data processor acting on their behalf. It adds that the customers' handling of personal data through the service is governed by their own privacy policy. The page shows revisions up to 27 August 2026. In plain words: the customer data in your LINE account is your responsibility.

The checklist

  1. List what you collect

    LINE name, LINE user ID, chat messages, notes and tags you add, and anything customers type or send: phone, address, photos.

  2. Say why, where customers join

    Use your greeting message, which can hold up to 5 balloons, to say what you keep and what for.

  3. Ask for the least you need

    If a booking needs a name and a time, do not ask for an ID number or an address.

  4. Keep sensitive details out of chat

    Do not ask customers to type health, religion or ID details into LINE. Send them to a proper form or ask them in person.

  5. Limit who can see it

    List your admins. Remove anyone who left. Give each person their own login.

  6. Set a retention rule

    Decide how long you keep leads and old chats, write it down, and follow it.

  7. Have an answer for requests

    If a customer asks what you hold or asks you to delete it, know who answers and how.

Worked example: a bakery with 800 LINE friends

A one page data list for a bakery (our own example, not a template approved by anyone)
WhatWhyWho sees itKeep for
LINE name and IDTo reply to the personOwner and 2 staffWhile they are a friend
Phone numberTo confirm a cake orderOwnerOrder date plus 90 days
Delivery addressTo deliver the orderOwner and driverOrder date plus 90 days
Notes: allergiesSo the cake is safeOwnerUntil the order is done

The retention periods in the last column are examples we chose to show the format. Your lawyer decides what is right for you. Allergy notes are health related, so the safer path is a short form where the customer ticks the allergy, rather than a free chat.

A sample consent line

"We use your LINE name and the details you send us to answer you and to handle your order. We keep order details for the period in our notice and do not sell them. Ask us here to see or delete what we hold." Put the link to your full privacy notice under it. Have your lawyer approve the wording before you use it.

Worked example: applying the list in an afternoon

  • The bakery has 800 LINE friends and takes about 40 cake orders a month.
  • Step 1: it writes the four-row list above, which takes 20 minutes.
  • Step 2: it adds two sentences to the greeting message about what it keeps and why.
  • Step 3: it moves allergy details from free chat to a short form with tick boxes, which reduces what sits in chat.
  • Step 4: it fixes a date in the calendar, 90 days after each order, to delete the phone number and address.
  • Result: one page, one greeting change, one form and one calendar reminder. The lawyer reviews that page, not 800 chats.

Questions people ask

Who is responsible for follower data, me or LINE?

LINE Thailand's privacy policy says customers who use its services are considered data controllers and LINE is their processor. So the responsibility for how you use your customers' data is yours.

Does the PDPA say how long I can keep chats?

We did not read the Act, so we cannot say. Ask a Thai lawyer, and write your own retention rule.

Can I collect health details in LINE chat?

Health details are sensitive. Our advice is to keep them out of chat. Ask a Thai lawyer what the law requires if your business needs them.

What to do next

This is general information, not legal or tax advice. Prices are before 7% VAT unless we say otherwise. LINE can change fees and screens at any time.

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