saudi-pdpl.com

Table of Contents

Article 1

Article 2

Article 3

Article 4

Article 5

Article 6

Article 7

Article 8

Article 9

Article 10

Article 11

Article 12

Article 13

Article 14

Article 15

Article 16

Article 17

Article 18

Article 19

Article 20

Article 21

Article 22

Article 23

Article 24

Article 25

Article 26

Article 27

Article 28

Article 29

Article 30

Article 31

Article 32

Article 33

Article 34

Article 35

Article 36

Article 37

Article 38

Article 39

Article 40

Article 41

Article 42

Article 43

Article 31

Without prejudice to Article (18) herein, the Controller shall maintain records, for such a period as required under the Regulations, of the Personal Data Processing activities, based on the nature of the activity carried out by the Controller. Such records are to be available whenever requested by the Competent Authority. The records shall contain the following information at a minimum:

  1. Contact details of the Controller.

  2. The purpose of the Personal Data Processing.

  3. Description of the categories of Personal Data Subjects.

  4. Any other entity to which Personal Data has been, or will be, disclosed.

  5. Whether the Personal Data has been or will be transferred outside the Kingdom or disclosed to an entity outside the Kingdom.

  6. The expected period for which Personal Data shall be retained.

FAQs

Yes, your personal data may be transferred outside Saudi Arabia—but only under specific lawful conditions: 

  • For performing contractual obligations either with you or agreements involving the Kingdom. 
  • To support national interests, operate services/benefits for you, or enable scientific research and administration. 
  • Only if the transfer does not undermine Saudi Arabia’s national security or vital interests.

Yes, an exception applies if the transfer is necessary to preserve your life or vital interests, or to prevent, diagnose, or treat disease. Such transfers may proceed even if the recipient country hasn’t been approved by the SDAIA. However, free flow of data must still not threaten national interests.

Controllers must follow a structured process (as outlined by SDAIA and PwC) before transferring data abroad: 

  1. Identify and log each cross-border transfer in their Record of Processing Activities (RoPA).  
  2. Confirm lawful basis for both processing (under PDPL Articles 5/6/10) and disclosure (under Article 15).  
  3. Ensure the transfer serves an allowed purpose (e.g., contractual, national interest, benefit, or research).  
  4. Confirm no risk to Saudi national security or vital interests and apply the principle of minimal data transfer.  
  5. Check if the destination is on SDAIA’s “adequate” whitelist: 
    a. If yes, minimal risk assessment may be sufficient. 
    b. If no, you must apply one of SDAIA’s approved safeguards: 
         -Standard Contractual Clauses (SCCs) 
         -Binding Corporate Rules (BCRs) 
         -Certification/accreditation from SDAIA-approved bodies 
  6. Conduct a risk assessment when sending sensitive data continuously or were using safeguards, in line with SDAIA’s risk assessment guidelines 
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