Telcowin
Book a Demo
Not sure where to start?
See the full picture across every solution area.
View all solutions
Need a hand?
Talk to our consultants about your project.
View all services
Our ecosystem
See how our partners fit together.
View all partners
Featured
See how RHB transformed their CX with Telcowin.
Read case study
About UsOur story & leadership Pledge 1%Giving back to our communities CareersJoin the Telcowinners PROTÉGÉ ProgrammeGraduate Salesforce pathway
Solutions Services Partners Insights About Support
← Back to Articles & Guides
Guide Data & Privacy 7 min read

Your IC Number, Their Database: What Subscriptions and Memberships Should and Should Not Ask For

Banks and e-wallets need your IC. Your gym, café app and newsletter usually do not. A plain guide to customer data privacy, for customers and for the businesses that collect it.

You have probably seen this form

You sign up for a gym, a café rewards app or a mall membership, and the form asks for your IC number. Then your full address. Then your date of birth. You fill it in, because everyone else does.

Now ask a simple question: what does a coffee loyalty app need my IC number for? Usually, nothing. And every extra field is one more thing that can leak, be sold or be misused.

This guide is for both sides of that form: customers who want to protect their data, and businesses that want customer data they can actually use without the risk.

When your IC really is needed

Some businesses must collect your IC by law. Banks and online banks have to verify every customer under anti-money laundering rules. E-wallets such as GrabPay, ShopeePay and Touch 'n Go eWallet need it before you can use their full features. Mobile lines, insurers and investment platforms also need to know exactly who you are.

For most other businesses, there is no such rule. A building guard, for example, has no right to keep or scan your MyKad, the National Registration Department said in 2025, and any processing of personal data by private companies falls under the Personal Data Protection Act.

Needs your ICRequired by law to verify you
Banks and online banksKnow-your-customer and anti-money laundering rules
E-walletsGrabPay, ShopeePay, Touch 'n Go eWallet, for full verification
Mobile linesSIM card registration
Insurers and investmentsPolicies, unit trusts, share trading
Government servicesTax, licences, healthcare
Only at one stepA reason may exist, not at sign-up
Your own e-invoiceOnly if you ask for one in your name
Claiming a big prizeTo verify the winner, not to enter
Age-restricted productsShow it to be checked; no need to copy
Car and equipment rentalsChecked at hand-over, kept only as long as needed
Usually no reasonAsk why, or leave it blank
Gym and club membershipsName, contact and payment are enough
Café and retail loyalty appsA phone number or email does the job
Newsletters and subscriptionsAn email address is enough
Events and webinarsName and email for the ticket
Building guardsNot allowed to keep or scan your MyKad
A general guide, not legal advice. Specific businesses may have a legal duty to collect more; if they do, they should be able to tell you which one. Sample card is fictional.

"It's for the e-invoice"

Since e-invoicing started, many customers have heard a new reason for handing over their IC: "it's for the e-invoice." Sometimes that is true. Often it is not.

For most everyday purchases you do not need an e-invoice in your name at all, and the seller can cover those sales with a consolidated e-invoice, without any of your personal details. Your details are only needed when you ask for an e-invoice in your own name, for example to claim tax relief. Then the invoice must carry your name, tax number or MyKad number, address and phone, and you will usually give an email so it can be sent to you.

Either way, e-invoicing is never a reason to collect an IC number when someone joins a membership or subscribes to a newsletter. And details collected for an e-invoice should be used for that invoice, not copied into a marketing list.

For everyday purchases you usually do not need an e-invoice in your name. If you ask for one, your name, tax number or MyKad, address and phone go on that invoice only. Based on LHDN guidance as summarised by tax advisers; Kedai Sample is fictional.

What the law expects from businesses

Malaysia's Personal Data Protection Act was updated in 2024, and the changes came into force in stages during 2025. For any business that runs subscriptions, memberships or marketing lists, a few points matter most:

Only what you need
Personal data must be collected for a clear purpose and kept no longer than needed. "We might use it one day" is not a purpose.
Report breaches
If a breach is likely to cause significant harm, the Commissioner must be told within 72 hours, and affected customers within 7 days after that.
Data protection officer
Businesses holding data on more than 20,000 people, or sensitive data on more than 10,000, must appoint one and register them.
Bigger penalties
Breaching the data protection principles can now mean fines of up to RM1 million, up to three years in prison, or both.

Indonesia's Personal Data Protection Law has been fully in force since October 2024, with fines of up to 2% of annual revenue. If you serve customers in both countries, design for both.

What a subscription or membership form should ask for

The best forms collect less, not more. Here is what that looks like for a typical rewards membership.

1Collect what the service needsA name and one way to reach the member is the core of most memberships.
2One contact is enough to startAsk for the second only if you will use it, and say what for.
3Less precise is often enoughBirthday month for a birthday treat; postcode for the nearest outlet.
4No IC, no full addressNeither is needed to collect points. If the data leaks, these are the fields that hurt customers most.
✓Separate, unticked consentOne box per channel, left empty, with a clear privacy notice and an easy way to change choices.
A membership form designed for less data. Kopi Sample and Aina are fictional.

What should never be in a subscription list

IC and passport numbers
Unless the law requires it for your business. If it does, store it apart from marketing data and mask it on screen.
Card numbers and passwords
Let a licensed payment provider hold card details. Never store passwords in plain text, or anywhere marketing can see them.
Health, religion and other sensitive data
These are sensitive personal data under the PDPA and need explicit consent. A newsletter has no reason to hold them.
Bought or scraped lists
People on them never agreed to hear from you. They hurt your sender reputation and your legal position.
Children's data
Without a parent's consent and a clear need, leave it out.
Data you cannot explain
If no one can say why a field exists, delete the field and the data in it.

Keep less, protect what you keep

Customer data is only useful if customers trust you with it. The businesses getting this right keep a single record per customer, store consent with proof of when and how it was given, mask sensitive fields so staff only see what their role needs, and delete inactive data on a schedule.

What a well-kept customer record looks like: only what is needed, consent with proof, sensitive fields masked, and a delete date. Fictional example.

On Salesforce, that means a consent and preference centre in Marketing Cloud or Account Engagement, consent stored on the customer profile in Data 360, field-level security so each team sees only what it needs, and Shield encryption and data masking for the few fields that must be protected, including in test copies of your data.

For customers: five habits that protect you

Ask why
If a form wants your IC, ask what it is for. If there is no good answer, leave it out or walk away.
Share less
Give a birthday month instead of a full date, a postcode instead of a full address.
Untick the boxes
Only agree to the messages you want, one channel at a time.
Never hand over your MyKad to be copied
Showing it to be checked is different from letting someone scan or keep it.
Use your rights
You can ask a business what data it holds on you, correct it, and stop marketing at any time.

For businesses: where to start

1
List every field you collect
For each one, write down why. Remove the ones without an answer.
2
Fix your forms
Drop IC numbers and full addresses where they are not needed, and split consent by channel.
3
Record consent properly
Store when, where and what the customer agreed to, on the customer record.
4
Lock down and clean up
Mask sensitive fields, limit access by role, and set a deletion schedule for inactive data.

How Telcowin helps

Telcowin has delivered Salesforce projects in Malaysia and Indonesia since 2012, and our delivery is ISO 9001 certified. On every project that touches customer data, we consult from two starting points: the local laws that apply to you, and the rules of your industry regulator.

That means designing against the PDPA and its 2024 amendments, the Personal Data Protection Commissioner's guidelines on data protection officers, breach notification, impact assessments and data protection by design, LHDN's e-invoicing rules where invoices are involved, and Indonesia's PDP Law for regional clients. Then we add your industry's own rules: Bank Negara Malaysia's technology risk requirements for banks and insurers, the Securities Commission's guidelines for capital markets, MCMC rules for telcos, OJK rules for financial services in Indonesia, and PCI DSS wherever card payments are involved.

We do not replace your lawyers or your DPO. We make sure the systems they rely on actually do what the policy says.

1AssessMap what you collect, where it lives and why.
  • Data inventory across systems
  • Impact assessment for high-risk processing
  • Gaps against the PDPA
2DesignPrivacy built in from the first form.
  • Collect only what is needed
  • Consent by channel, with proof
  • Retention and deletion rules
3BuildControls in the platforms you use.
  • Role-based access in Salesforce
  • Encryption and masking for sensitive fields
  • Governed data flows with Boomi
4RunReady for the day something goes wrong.
  • Breach response plan and timelines
  • Access reviews and audit trails
  • Support for your DPO
Local laws and industry regulations we design against
Malaysia PDPA 2010 and 2024 amendmentsPDP Commissioner guidelinesLHDN e-invoicing rulesBNM RMiT for banks and insurersSecurities Commission technology risk guidelinesMCMC rules for telcosIndonesia PDP LawOJK rules for Indonesian financial servicesPCI DSS for card paymentsSalesforce and Boomi security best practice
How Telcowin approaches customer data projects. We work alongside your legal counsel and data protection officer; this is not legal advice.

Govern it end to end, with Boomi

Fixing one form is a start. The harder problem is everything already out there: customer data copied into spreadsheets, old systems nobody switched off, and integrations moving personal data between apps every minute. Privacy only holds if it is governed across all of them.

Boomi sits between your systems, which makes it the natural place to govern the data flowing through them. It can identify sensitive data across sources such as Salesforce, databases, files and spreadsheets. Boomi Data Hub builds a single golden record for each customer, with role-based access, masking, tagging and an audit trail. Row- and column-level masking and data lineage help teams use data for reporting and AI without exposing what they should not see.

The result is data you can stand behind when a customer asks what you hold, when the Commissioner asks how you protect it, and when your AI tools need data they can safely use. See how Telcowin works with Boomi.

Where data lives
Website and app formsSign-ups, memberships
POS and e-commerceOrders, loyalty
Spreadsheets and old systemsEvent lists, exports
Core and finance systemsBilling, accounts
Governed by Boomi
One trusted customer record
1
Find sensitive dataSpot personal and sensitive fields across connected systems, including old ones.
2
One golden recordData Hub matches and cleans duplicates into a single version of each customer.
3
Control who sees whatRole-based access and masking, so each team only sees what it needs.
4
Prove itTagging, lineage and audit trails show where data came from and who touched it.
Where it is used
Salesforce CRMSales and service
MarketingConsented messages only
Analytics and AIMasked where needed
Data governance with Boomi: find it, clean it, control it, prove it, before customer data reaches the teams and AI tools that use it.

Sources: Malay Mail: NRD says security guards cannot ask for or scan MyKad (June 2025); Hogan Lovells: Malaysia mandatory data protection officer guideline; PDPA amendments guide: phases, breach notification and penalties; Incorp: PDPA compliance guide; Legal 500: Indonesia data protection regulatory landscape; CCS & Co: LHDN e-invoice FAQs for individual buyers; ClearTax: data fields required for an e-invoice in Malaysia; Boomi: de-risk your data to improve compliance and governance; Boomi: Data Catalog and Preparation. This article is general information, not legal advice. Check the Personal Data Protection Commissioner's latest guidelines at pdp.gov.my.

Customer data customers can trust

We help businesses collect less, protect more and still know their customers, with consent, masking and governance built in across Salesforce and Boomi.