Data Strategy Briefing — September 24, 2021
Saudi Arabia issued its Personal Data Protection Law, establishing comprehensive processing obligations, localisation rules, and SDAIA oversight ahead of a one-year grace period.
Executive briefing: Saudi Arabia promulgated the Personal Data Protection Law (PDPL) via Royal Decree M/19 on 24 September 2021, creating the Kingdom’s first comprehensive data protection regime. The law, overseen by the Saudi Data & Artificial Intelligence Authority (SDAIA), introduces lawful basis requirements, data subject rights, controller registration duties, localisation expectations, and cross-border transfer restrictions with limited exemptions.
Key governance checkpoints
- Legal bases and records. Catalogue processing activities against PDPL lawful bases and prepare records of processing in Arabic for SDAIA inspection.
- Localisation and transfers. Identify datasets subject to localisation or prior authorisation before transferring personal data outside the Kingdom.
- Data subject rights. Implement procedures for access, correction, deletion, and withdrawal of consent within statutory timelines.
Operational priorities
- Governance structure. Appoint a qualified data controller representative in the Kingdom and define reporting lines to senior leadership.
- Risk assessments. Develop impact assessment methodologies for high-risk processing, biometrics, and cross-border transfers.
- Incident management. Align breach detection, notification, and remediation playbooks with PDPL reporting requirements.
Enablement moves
- Monitor SDAIA regulations and executive rules released during the law’s grace period to refine compliance roadmaps.
- Coordinate with sector regulators—such as SAMA and the Communications, Space & Technology Commission—for sector-specific privacy controls.
Sources
- Personal Data Protection Law (Royal Decree M/19 of 17/2/1443H)
- SDAIA announcement on the Personal Data Protection Law
Zeph Tech guides Saudi organisations through PDPL readiness assessments, localisation strategies, and SDAIA engagement playbooks during the implementation grace period.