Personal data refers to any information that identifies an individual, either directly or indirectly. This includes:

• Name, ID numbers, email addresses, phone numbers, and IP addresses.
• Sensitive data such as health, biometric, financial, and religious information. Employee data is indeed considered personal data and must be handled in compliance with PDPL.

The list of countries with “adequate” data protection standards is anticipated to be released by SDAIA. However, there is currently no confirmed timeline. It is recommended for organizations to monitor updates directly from SDAIA or through official government announcements.

To ensure that your Binding Corporate Rules (BCR) comply with SDAIA guidelines:

• Compare your BCR against SDAIA’s published requirements (SCC Clause).
• Validate the BCR framework for transparency, accountability, security, and consent mechanisms.
• Consult legal/privacy experts to perform a compliance gap analysis.

A  Data Protection Officer (DPO) can be a dedicated role or an existing resource within the organization, depending on the size and complexity of the organization. If the role is assigned to an existing resource, departments such as legal, compliance, or IT are typically considered appropriate due to their alignment with privacy and governance requirements. The DPO must be adequately skilled and independent in overseeing compliance.

 If your organization processes a limited amount of personal data (e.g., only employee data) and does not handle sensitive or large-scale data, appointing a DPO may not be mandatory. However, having a point of contact for privacy-related matters is recommended to ensure compliance.

It is advised to register the organization with SADIA. To determine if your organization is required to register, it is best to verify this on the SADIA website.

Yes, the requirement to appoint a DPO depends on the organization’s data processing activities. Organizations should assess their size, data volume, and sensitivity to determine compliance obligations and check if their primary operations involve personal/sensitive personal data processing.

Yes, it is considered good practice to:

• Notify employees of the updated Privacy Policy.
• Obtain their acknowledgment to ensure transparency and compliance. This approach demonstrates accountability and aligns with PDPL requirements for lawful processing.

Yes, the PDPL document is publicly available and can be accessed on SDAIA’s official website or through government legal publications.

The PDPL applies to all personal data, including:

• Internal employee data (e.g., HR records, payroll data).
• External personal data (e.g., customer or client information).

Examples of sensitive and non-sensitive personal data include:

• Sensitive Personal Data: Health records, biometric data, financial information, religious beliefs, or political affiliations.
• Non-Sensitive Personal Data: Name, phone number, email address, or publicly available information.

Credit data refers to any information related to an individual’s financial status, such as:

• Credit scores and reports.
• Loan or repayment history.
• Credit card information.

Yes, the PDPL applies to any entity processing the personal data of individuals residing in Saudi Arabia, regardless of where the organization is located. If you handle such data, compliance with PDPL requirements is necessary.

The presentation file is attached to this email.

Our consultants possess extensive experience in data privacy, compliance, and cybersecurity. They are well-versed in global regulations such as KSA PDPL, UAE PDPL, Qatar PDPPL, GDPR, CCPA, and other data privacy regulations. We have a team with certified expertise across the GCC, Europe, and other international markets.

The effective date of the Personal Data Protection Law (PDPL) in Saudi Arabia is September 14, 2023.