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:
- 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.
- 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.