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Project Description
UNPROMPTED Pte. Ltd. is a Singapore-based AI platform designed for consulting firms. It offers a secure "provenance workspace" to extract, organize and utilize insights from any source. Built by former consultants, the platform supports the entire project lifecycle from data ingestion to verified deliverables. It ensures accuracy, traceability and human verification. A key differentiator is the "Fact Layer" which serves as a single source of truth with full lineage tracing. As the company scales internationally it operates with a security-first mindset to integrate strict client confidentiality and ethical AI deployment into its product DNA.
The project aimed to design a comprehensive compliance framework addressing Singapore PDPA, EU GDPR, and the emerging EU AI Act. The scope included a multi-layered analysis to align the existing security and privacy measures at UNPROMPTED with evolving global regulations, development of compliance toolkits, and recommendations for governance and risk management. The methodology involved benchmarking global best practices, conducting interviews with UNPROMPTED leadership, and mapping data flows across critical systems. The ultimate goal was to enable UNPROMPTED to validate readiness for global enterprise adoption and support client due diligence. This initiative prioritized embedding advanced governance into company operations to support sustainable global expansion.
Project Outcomes
Key deliverables included:
- Compliance Toolkit: PDPA/DPTM SS 714:2025 checklist, GDPR checklist, and AI Act risk classification matrix.
- Gap Analysis: Formalized DPO appointments, breach management plans, retention policies, RoPA, DPIA frameworks and consent management.
- Recommendations: Solidify DPO and EU representative roles, update privacy policies, implement DPIA processes, and strengthen consent controls.
Beyond these, the project delivered a phased roadmap for compliance maturity, including immediate optimizations and long-term governance enhancements. The toolkit was designed to be modular, allowing UNPROMPTED to adapt as regulations evolve. Additionally, the team proposed a training curriculum for staff to build awareness and accountability in data handling and AI ethics.
The SMU-XL Capstone Project has positioned UNPROMPTED to navigate complex regulatory landscapes confidently. Through structured analysis and strategic recommendations, the project delivered a roadmap for robust governance and operational resilience. This transformation ensures that UNPROMPTED exceeds standard client expectations for transparency and security. This foresight distinguishes UNPROMPTED in a competitive market where trust is paramount. The project also reinforced the importance of ethical AI practices aligning UNPROMPTED with both global standards and emerging norms.
Implementation and Immediate Benefits
The governance framework introduced clear accountability, risk tier classification, and phased compliance implementation. Immediate benefits include enhanced transparency, expedited readiness for audits, and improved client confidence in UNPROMPTED’s data handling practices. The phased approach minimized operational disruption, starting with building upon established protocols and scaling to advanced AI governance. By integrating compliance into product development cycles, UNPROMPTED ensures continuous alignment to maintain development velocity. The project also enabled the company to respond proactively to client due diligence requests, strengthening its market position.
Tools and Resources
The project leveraged international standards and best practices, including:
- PDPA/DPTM SS 714:2025 for Singapore compliance.
- EU GDPR for data protection and privacy.
- EU AI Act for AI system risk management.
Supporting tools included compliance checklists, role matrices, and risk assessment templates. The team also developed a governance dashboard to monitor compliance KPIs, such as breach response time, DPIA completion rates, and AI bias metrics. These resources empower UNPROMPTED to maintain compliance dynamically, adapting to regulatory changes without compromising innovation.
Ongoing Improvements
Future initiatives include completing additional certifications, advancing bias mitigation strategies, and enhancing transparency through public security and privacy reports. The company plans to scale compliance culture through continuous training, automated monitoring tools, and integration of ESG principles into AI development. Long-term, UNPROMPTED aims to establish itself as a compliance leader in the AI sector, leveraging its governance framework as a competitive advantage.
Conclusion
The compliance framework developed through this project exemplifies strategic foresight and operational excellence. By establishing a robust architecture to meet global standards and adopting a proactive governance model, UNPROMPTED is well-positioned for sustainable growth and leadership in the AI sector. The project not only solidified readiness for regulatory requirements but also laid the foundation for ethical innovation and long-term resilience. As AI regulations continue to evolve, UNPROMPTED’s commitment to compliance will serve as a cornerstone of its brand integrity and client trust.
Feedback from Partner
I'm extremely satisfied with the outcome and the clear actionability of the project learners’ recommendations, as well as the additional background that will allow us to deep dive or easily check details and apply templates. As we're currently in the process of obtaining privacy and security certifications, we will be leveraging many of the project findings immediately.
Erik Ligtenberg, Co-founder, UNPROMPTED Pte. Ltd. (https://wellknownlabs.com/)
This project provided a great opportunity to bridge the gap between theory and practice to solve multi-jurisdictional compliance (PDPA, GDPR & EU AI Act). We are incredibly proud to have developed a basic framework that supports UNPROMPTED’s international growth and ensures compliance with data governance requirements.
Thank you to Professor Venky, Professor Gary, Lyndon, and our project sponsor, Erik, for their invaluable feedback and support throughout the SMU Project XL journey.
Josephine Ong Huey Ruh, IPM SMU-XL Student
A true reflection of strong teamwork with my fellow participants-Josephine Ong, Andrew Leong and Chee Kok Seng, the unwavering support and encouragement from my project sponsor Erik Ligtenberg, Unprompted , and the invaluable guidance of SMU professors Prof Gary , Prof Venky who challenged us to think critically and apply our learning in real-world contexts. Thank you to SMU-X Lyndon Teoh who contributed to this meaningful learning journey—this recognition reinforces my belief in lifelong learning and the power of collaboration.
Wendy Chua, IPM SMU-XL Student
I am truly grateful for the opportunity to participate in the SMU-XL Project on Data Protection and Governance. The project was highly realistic and provided an excellent platform to apply the concepts and knowledge we have gained throughout the course in a practical setting.
Special thanks to Prof. Venky and Prof. Gary for their invaluable guidance. Their extensive experience and practical advice helped us set realistic expectations and navigate the project effectively. Their support made a significant difference in ensuring that the learning experience was meaningful and impactful.
I would also like to express my appreciation for the outstanding administrative support provided by Lyndon. He was prompt, clear, and patient in addressing our queries. His detailed instructions on submission requirements, timely reminders, and practical advice—based on his recent experience with the SMU-XL project—were extremely helpful. We are truly fortunate to have had his support throughout the process. Overall, this experience has been enriching and has strengthened our understanding of data protection and governance in real-world scenarios. Thank you to the entire team for making this journey so rewarding.
Andrew Leong, IPM SMU-XL Student
The overall SMU-XL Capstone Project experience was extremely valuable and rewarding. It provides us opportunities for growth in strengthening our analytical and critical thinking, problem-solving, decision making, active listening, communication, collaboration, adaptability (planning, time management, flexibility, resilience, and working under pressure), leadership, interpersonal & teamwork (conflict resolution, rapport-building). These are positive, effective, transferable skills which enable career growth, and in our learning education.
The Professors and SMU-X Office displayed remarkable professionalism, responsiveness and commitment, providing clear and consistent communication, ensuring all team members remain well-informed throughout the project, ensuring that we received prompt guidance, excellent advice, helpful feedback, and access to all the necessary resources. The sponsor provides prompt response and excellent advice. I had an extremely dedicated and awesome team who have shown accountability, willingness to support one another, motivated, and fully committed to producing high quality projects.
I am extremely grateful to SMU for their support and guidance for making this a valuable and memorable experience and journey.
Chee Kok Seng, IPM SMU-XL Student
Partner: UNPROMPTED Pte. Ltd.
Company Type: MNC/SME/Startup
Navigating Multi-Jurisdictional Compliance for AI-Driven Platform Expansion
Theme(s):
Digital Transformation, Growth in Asia
Instructor:
Professor Gary PAN
School:
SMU Academy
Course:
Digital Economy Capstone (Industry Practice Masters)