Data Breach Notification Obligations | Saudi PDPL

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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 23

Without prejudice to this Law, the Regulations shall set out additional controls and procedures for the Processing of Health Data in a manner that ensures the privacy of the Data Subject and protects their rights under this Law. Such additional controls and procedures shall include the following:

  1. Restricting the right to access Health Data, including medical files, to the minimum number of employees or workers and only to the extent necessary to provide the required Health Services.

  2. Restricting Health Data Processing procedures and operations to the minimum extent possible of employees and workers as necessary to provide Health Services or offer health insurance programs.

FAQs

Yes. The law provides specific exemptions under Article 23. These exemptions include: 

  • Personal or family use : if you’re processing personal data strictly for your own private or family activities, PDPL provisions (e.g., on consent, data subjects’ rights, etc.) do not apply.  
  • Regulatory exceptions : The Implementing Regulations also outline other exemptions, such as when processing is necessary for national security, public health emergencies, or compliance with legal obligations or court orders.

A Controller must conduct a formal assessment by: 

  • Identifying the exemption e.g.: This is personal/family use, or This is for public health. 
  • Documenting the rationale: explaining why the exemption applies and how it meets legal criteria. 
  • Ensuring the scope is limited: exemptions should be narrowly applied and not used to bypass broader compliance. 
  • Keeping records: including the exemption analysis and decisions so they can justify it to regulators if questioned.

If SDAIA (or another competent authority) determines the Controller misused an exemption: 

  • The Controller may be called to explain or provide supporting records. 
  • The exemption may be revoked, requiring the Controller to bring processing into full compliance with PDPL obligations. 
  • Enforcement actions may follow, such as fines, correction orders, or other penalties appropriate to the violation.
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