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Decision 778/QD-BCA-A05 is an administrative decision issued by the Ministry of Public Security (MPS) Department A05 that operationalizes six specific administrative procedure forms defined under Decree 356/2025/ND-CP. Where Decree 356 prescribes the forms and their data content, Decision 778 specifies the procedural mechanics: the receiving unit within MPS, the exact steps in the filing and review process, the handling procedures for supplement requests, and the administrative procedure codes (DLCN-HC procedure identifiers) that organizations must reference when initiating each type of filing. The Decision is currently in force and applies to all organizations subject to the PDPL that must interact with MPS through these six form types.
Decision 778 applies to the six Decree 356 forms that require direct procedural interaction with the MPS A05 unit: Mau so 01a (Cross-Border Transfer – Controller), Mau so 01b (Cross-Border Transfer – Processor), Mau so 02a (DPIA Dossier – Controller), Mau so 02b (DPIA Dossier – Processor), Mau so 03a (Dossier Update – Controller), and Mau so 03b (Dossier Update – Processor). Each of these forms has an associated DLCN-HC procedure code that must be correctly cited in the filing package. Organizations that omit the procedure code or cite the wrong code for the form type create administrative friction that can delay MPS processing.
The procedural significance of Decision 778 lies in the gap it fills between the form requirement (defined by Decree 356) and the interaction requirement (how MPS A05 actually processes that form). Compliance teams that prepare technically correct form templates but do not understand the A05 procedure mechanics can still encounter delays at the authority interaction stage. Decision 778 is the practitioner's reference for ensuring that a correctly prepared form arrives through the correct procedure channel and triggers the correct MPS processing workflow.

The Vietnam Personal Data Protection Law (Law 91/2025/QH15) establishes the filing obligations – when organizations must interact with MPS. Decree 356/2025/ND-CP specifies the forms and data structures for those interactions. Decision 778/QD-BCA-A05 specifies the procedural mechanics within the MPS A05 unit for handling those interactions. For a full view of the statutory obligations that trigger these procedures, see the Vietnam PDPL (Law 91/2025/QH15) compliance page. For the complete Decree 356 form catalog, see the Decree 356 PDPL Implementation page.
Decision 778 sits at the most granular level of the PDPL compliance instrument hierarchy: Law 91 (statutory obligations) – Decree 356 (administrative forms and data structures) – Decision 778 (MPS A05 procedural mechanics). A practitioner implementing PDPL compliance must understand all three levels to execute MPS interactions correctly. Decision 778 is specifically relevant for the A05 unit interactions and does not govern all MPS interactions – only the six procedure types it explicitly operationalizes.
For organizations that rely on a compliance platform to manage PDPL filings, Decision 778 is the instrument that determines whether the platform's filing workflow matches what MPS A05 actually expects to receive. A platform that implements Decree 356 forms but does not model the Decision 778 procedural steps will produce correctly formatted documents that may still follow the wrong procedure sequence when submitted.
| Form | Procedure Type | Receiving Unit | Procedure Code (DLCN-HC) |
|---|---|---|---|
| Mau so 01a | Cross-Border Transfer Impact Assessment – Controller | MPS A05 | DLCN-HC-01a |
| Mau so 01b | Cross-Border Transfer Impact Assessment – Processor | MPS A05 | DLCN-HC-01b |
| Mau so 02ar | DPIA Dossier Submission – Controller | MPS A05 | DLCN-HC-02a |
| Mau so 02b | DPIA Dossier Submission – Processor | MPS A05 | DLCN-HC-02b |
| Mau so 03a | Dossier Update Notice – Controller | MPS A05 | DLCN-HC-03a |
| Mau so 03b | Dossier Update Notice – Processor | MPS A05 | DLCN-HC-03b |
Note: Procedure codes shown as representative identifiers. Verify against the current Decision 778 text for confirmed DLCN-HC code values.
Each of the six procedures follows a consistent sequence of steps within the MPS A05 processing workflow:
| Step | Action | Party Responsible | Documentation Required |
|---|---|---|---|
| 1 | Filing submission with DLCN-HC procedure reference | Organization | Completed Mau so form with official template ID and procedure code |
| 2 | Dossier receipt and completeness check | MPS A05 | Receipt acknowledgment |
| 3 | Substantive review | MPS A05 | Review period begins (30 calendar days) |
| 4a | Supplement request (if dossier is incomplete) | MPS A05 | Supplement request specifying required additional information |
| 4b | Supplement response | Organization | Supplementary documentation (15 working days) |
| 5 | Final determination | MPS A05 | Acceptance notification or rejection with reasons |
| 6 | Resubmission if rejected | Organization | Revised dossier (10 working days after rejection) |
| Obligation | Timeline | Notes |
|---|---|---|
| MPS dossier review period | 30 calendar days from receipt | Resets if supplement requested |
| Organization supplement response | 15 working days from supplement request | Failure to respond within window may close the procedure |
| Resubmission after rejection | 10 working days from rejection notification | |
| Dossier update notice after material change | Within the window prescribed by Decree 356 | Triggers Mau so 03a or 03b under Decision 778 procedure |

ComplianceOne models the Decision 778 A05 procedural sequence as a named filing workflow state machine, separate from but integrated with the Decree 356 form preparation workflow. When a practitioner initiates a filing that falls within one of the six Decision 778 procedures, the platform configures the filing lifecycle to track the A05 procedural steps – not just the generic filing states – ensuring that the 30-day review clock, 15-day supplement response window, and 10-day resubmission timeline are all tracked against the MPS procedure timeline rather than an internal deadline only.
The DLCN-HC procedure code for the applicable procedure is pre-configured within each relevant form template in the Compliance Forms module. When a practitioner generates a Mau so 02a (DPIA Dossier – Controller), the form is pre-labeled with both the Decree 356 template ID and the corresponding DLCN-HC procedure code. This removes a common error mode where the form content is correct but the procedure reference is missing or mismatched. The filing workflow routes the completed dossier through internal review and approval before submission, with the approval record captured in the audit trail.
For supplement request management, the platform creates a linked supplement response task when an MPS A05 supplement request is logged. The task is pre-assigned to the practitioner responsible for the original filing, pre-populated with the supplement deadline (15 working days from the supplement request date), and linked to the original filing record so that the complete interaction history – initial submission, supplement request, supplement response, and final determination – is captured in a single, navigable evidence record. This complete procedural record is available for export as an audit-grade evidence pack at any point in the lifecycle.
Provides Mau so 01a, 01b, 02a, 02b, 03a, and 03b templates with both Decree 356 template IDs and DLCN-HC procedure codes.
Explore Compliance FormsManages the DPIA dossier preparation and filing lifecycle aligned to the Mau so 02a/02b A05 procedure sequence.
Explore IncidentsManages MPS supplement request loops for breach notification filings (Mau so 08, which follows Decree 356 but not a Decision 778 procedure).
Explore Data MappingCaptures the complete MPS interaction history for each Decision 778 procedure: submission, supplement, response, and determination.
Explore Audit TrailOrganizations implementing Decision 778 A05 procedure compliance should confirm:
Ready to see how ComplianceOne executes Decision 778 A05 filing procedures with DLCN-HC procedure codes and deadline tracking? Request a demo tailored to your organization's PDPL filing operations.

Decree 356 tells you which form to use and what data to put in it. Decision 778 tells you how to submit that form to MPS A05 – which procedural channel to use, which DLCN-HC code to cite, how MPS will handle the review, and what happens if MPS requests additional information. Both layers are required for a successful MPS filing. Getting the form right but citing the wrong procedure code, or submitting through the wrong MPS channel, creates administrative friction even if the form content is technically correct.
The six procedures follow the same general sequence (submission, review, supplement if needed, determination), but the receiving unit, review criteria, and acceptable supplement documentation may differ by form type. DPIA procedures (Mau so 02a/02b) involve a substantive assessment of the impact assessment methodology, while dossier update procedures (Mau so 03a/03b) involve a comparison against the originally submitted dossier. Cross-border transfer procedures (Mau so 01a/01b) involve assessment of the transfer risk basis. ComplianceOne models each procedure type separately to reflect these differences.
Decision 778, in conjunction with Decree 356, requires organizations to notify MPS of material changes to a previously submitted DPIA dossier or cross-border transfer filing. Material changes include changes to the categories of personal data processed, changes to the purposes of processing, significant changes to the systems involved, or changes to the legal basis for processing. The threshold for "material change" is defined in Decree 356. When such a change occurs, Mau so 03a (controller) or 03b (processor) is filed through the A05 procedure, linking the update to the original filing.
Decision 778/QD-BCA-A05 specifies MPS A05 administrative procedures for six forms: Mau so 01a, 01b, 02a, 02b, 03a, and 03b. These procedures define additional procedural steps, the specific MPS A05 unit responsible for receiving the filing, and procedural timelines that apply on top of the base Decree 356 requirements. ComplianceOne models these Decision 778 procedures within the filing workflow. For a full breakdown of those procedures, see the MPS A05 Administrative Procedures page.
Yes. When an MPS A05 supplement request is logged in the system (via the practitioner recording the supplement request receipt), the platform calculates the 15-working-day deadline from that date and creates a deadline-tracked task for the supplement response. If the deadline approaches without a response being submitted, escalation notifications can be configured. The supplement response, when completed, is linked to the original filing record and the supplement request in the audit trail.

Test MPS A05 procedure workflows with your team – filing lifecycle management, DLCN-HC procedure code configuration, and supplement request handling.

Talk to our team about Decision 778 procedure configuration, deadline tracking, and how ComplianceOne models A05 interactions for your organization.