Decree 356/2025/ND-CP: Tightening Data Governance and New Cybersecurity Benchmarks in Vietnam

The information security landscape in Vietnam has marked a significant milestone with the issuance of Decree 356/2025/ND-CP, which replaces and upgrades the regulations previously set by Decree 13/2023/ND-CP. Amidst a surge in Remote Code Execution (RCE) exploits and data breaches via unsecured APIs, understanding and implementing this Decree is no longer just a legal obligation—it is an existential necessity for modern enterprises.

1. Analyzing the Shift: From Decree 13 to Decree 356/2025

Decree 356/2025 is not merely a succession of previous laws; it is a robust upgrade in terms of definitions and enforcement penalties.

• Expanded Scope of Sensitive Data: The decree now includes online user behavioral data and next-generation biometric identifiers (such as vein patterns and keystroke dynamics).

• Consent Management: Absolute clarity is now mandatory. "Default consent" or "forced consent" achieved through Dark Patterns (hidden terms in user interfaces) will be treated as severe violations.

• Accelerated Incident Reporting: The window for notifying the Department of Cybersecurity and High-Tech Crime Prevention (A05) upon discovering a data leak has been significantly tightened.

2. Technical Vulnerabilities Leading to Non-Compliance

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From a cybersecurity perspective, failing to comply with Decree 356 often stems from specific technical flaws:

• Broken Object Level Authorization (BOLA): This allows unauthorized users to access others' personal data by tampering with IDs in API requests.

• Insecure Storage: Storing sensitive personal data in plaintext within databases makes it an easy target for attackers utilizing SQL Injection.

• Lack of Data Flow Monitoring: Organizations often fail to monitor cross-border data transfers to third parties, violating regulations concerning Data Protection Impact Assessments (DPIA).

3. Departmental Compliance Roadmap

To meet the standards of Decree 356/2025, every department within an organization must execute a specific action plan:

3.1. Board of Directors & Legal/Compliance

• Review all partner and customer contracts to update data protection clauses to 356 standards.

• Establish and file DPIA dossiers as required by the Ministry of Public Security.

3.2. IT & Cybersecurity

• Deploy Data Loss Prevention (DLP) solutions to monitor and prevent the leakage of sensitive information.

• Conduct periodic Vulnerability Assessments and Penetration Testing (VAPT) to identify flaws like Broken Authentication or Security Misconfigurations.

• Adopt a Zero Trust model: Never trust, always verify every access request to sensitive data zones.

3.3. Marketing & Sales

• Audit lead collection campaigns. Ensure separate "Consent" checkboxes exist for each specific data use (e.g., Advertising, Analytics, Third-party sharing).

• Systematize CRM tools to support the "Right to be forgotten" (data deletion) upon user request.

3.4. Human Resources (HR)

• Conduct security awareness training to prevent Phishing attacks aimed at stealing credentials for HR management systems.

• Strictly manage the personal data of candidates and current employees according to the Decree's new classifications.

To meet the standards of Decree 356/2025, every department within an organization must execute a specific action plan

4. Comprehensive Compliance Solutions by IPSIP

Recognizing the pressure enterprises face under these new regulations, IPSIP offers a specialized service ecosystem to ensure thorough compliance with Decree 356/2025:

• Data Protection Compliance Consulting: Expert support in building DPIA dossiers and legally-sound data protection workflows. [Learn more about IPSIP Consulting].

• VAPT Services: Proactively scanning and patching security vulnerabilities before they can be exploited.

• Security Operations Center (SOC): 24/7 incident detection and response to ensure your organization meets mandatory reporting timelines.

Note: The content above is synthesized based on professional analysis and forecasts regarding the cybersecurity legal roadmap in Vietnam. Specific vulnerability data and violation cases are for reference only, based on field reports from the IPSIP expert team. Enterprises should consult with legal counsel and technical specialists for their specific circumstances.

References:

• Ministry of Public Security Web Portal.

• Vietnam Law Database (luatvietnam.vn).

• IPSIP Insight Report: Decoding Decree 356/2025.

• Global Data Security Standards (GDPR) and their alignment in Vietnam.