The Praxis Systems' Malaysian Privacy Notice Methodological Codebook: PDPA 2010 and Act A1727 Indicators

This codebook specifies the instrument used in The 43-Point Gap (DOI 10.5281/zenodo.21764557): the indicator framework, scoring architecture, evidentiary rules, decision procedures and known error of an AI-assisted method for assessing Malaysian privacy notices against the Personal Data Protection Act 2010 and the Personal Data Protection (Amendment) Act 2024. It is written so that a regulator, legal adviser or academic reviewer can trace any reported score to its statutory anchor, bound the claim against stated limitations, and contest a score through a published correction procedure. Contents. The evidence base and what the instrument can and cannot observe; a three-group classification distinguishing obligations that must be disclosed in a notice (Group A) from those satisfiable through other channels (Group B) and those carrying no disclosure duty at all (Group C), applied to sections 7, 7(3), 9, 12A, 12B, 43A and 129; the layer architecture and ordinal scoring criteria; risk-horizon classification in place of published coefficients; documentary bands D1–D4; representative indicator profiles; applicability, missing-value codes and edge-case gateways; measured error, validation status, version control and dispute procedure. Disclosure boundary. Section 18 publishes a complete register of eighteen framework elements, each marked published or withheld with the reason and the consequence stated. Detection logic, prompts, phrase libraries, numeric coefficients and pipeline internals are retained as confidential business information; no limitation, adverse finding or measured error is withheld. Measured limitations published in full include a 55% retrieval miss rate on the one indicator audited, a length-sensitivity correlation of ρ=0.365, and the absence of any human-rater validation. This document is a framework specification, not an implementation specification: it will not permit the instrument to be reproduced. It is not legal advice, a compliance certification, or an audit standard. Not peer reviewed. Licensed CC BY-ND 4.0; the implementation is not licensed.