PDPL Checklist

Introduction
The Saudi Personal Data Protection Law (PDPL), initially introduced in 2021 and amended in
March 2023, aims to safeguard personal data and uphold privacy rights. It came into effect on
September 14, 2023, with full enforcement commencing on September 14, 2024. The Saudi Data
& Artificial Intelligence Authority (SDAIA) oversees its implementation, ensuring compliance
by organizations operating within or outside Saudi Arabia that process personal data of Saudi
residents.
Failure to comply with the PDPL can result in severe penalties, including fines and
imprisonment. This document provides a structured compliance checklist tailored to your
company’s operations in Saudi Arabia.
Compliance Checklist
1. Registration Requirements
 Obligation: Register as a Controller with the Saudi Data & Artificial Intelligence
Authority (SDAIA).
o Provide details of data processing activities.
o Include information on the appointed Data Protection Officer (DPO), if
applicable.
 Steps to Register:
1. Access the SDAIA registration platform.

2. Submit a completed registration form with:
 Organization’s name and contact details.
 Nature and scope of data processing activities.
 Details of cross-border data transfers (if applicable).
3. Obtain the registration certificate (valid for up to five years).
 Renewal: Ensure timely renewal of the registration certificate and update SDAIA of any
changes in data processing activities or organizational structure.
2. Data Processing Records
 Obligation: Maintain detailed records of all personal data processing activities to ensure
transparency and accountability.
 Required Details:
o Categories of personal data processed.
o Purposes and legal basis for data processing.
o Retention periods.
o Measures implemented for data security and protection.
o Third-party vendors or entities with access to the data.
 Retention: Preserve these records for at least five years or as mandated by SDAIA.
3. Appointment of a Data Protection Officer (DPO)
 When Required:
o If your company processes sensitive personal data or conducts large-scale data
processing.
o Activities involve systematic monitoring of data subjects (e.g., behavioral
analytics or location tracking).
 DPO Qualifications:
o Academic qualifications and experience in data protection.
o Knowledge of risk management and incident handling.
o Familiarity with Saudi PDPL and global privacy regulations.
o Proven honesty and integrity.
 Reporting Structure:
o If governed by SDAIA rules: Report to the Chief Data Officer.
o Otherwise: Report directly to the Board of Directors or Executive team.
 Documentation: Retain records of DPO appointment and contact details on the SDAIA
platform.
4. Privacy Notices and Consent Management
 Transparency: Ensure privacy notices include:

o Purpose and scope of data collection.
o Categories of personal data collected.
o Data subject rights under the PDPL (e.g., access, correction, deletion).
o Cross-border data transfer details, if applicable.
 Consent Requirements:
o Obtain explicit consent for collecting and processing sensitive personal data.
o Maintain consent records for at least five years.
o Provide mechanisms for withdrawal of consent and ensure immediate cessation of
processing upon withdrawal.
5. Cross-Border Data Transfers
 Obligation: Transfers of personal data outside Saudi Arabia are permissible only if:
1. National security or vital interests are not prejudiced.
2. Adequate guarantees for confidentiality and protection are in place.
3. Transfers are limited to the minimum necessary data.
4. Approval is obtained from SDAIA.
 Documentation:
o Maintain detailed records of all cross-border transfers, including recipient details

and protection measures.
o Retain these records for at least five years.
 Annual Review: Conduct annual audits of cross-border data transfer arrangements.

6. Data Subject Rights Management
 Obligation: Facilitate the exercise of data subject rights, including:

o Access, correction, and deletion of personal data.
o Objection to data processing.
 Implementation Steps:
1. Develop clear procedures for handling data subject requests.

2. Provide acknowledgment within three business days.
3. Fulfill requests within 30 days unless extended with SDAIA approval.
 Tracking: Maintain logs of all requests and actions taken.
7. Data Breach Response Plan
 Notification Timeline: Notify SDAIA within 72 hours of becoming aware of a breach.

 Incident Response Steps:
1. Contain the breach immediately.
2. Conduct a preliminary investigation within 24 hours.
3. Notify affected individuals, if necessary, within 72 hours.
4. Submit a detailed incident report to SDAIA within seven days.
 Post-Breach Actions: Conduct a root cause analysis and implement corrective measures.
8. Vendor and Third-Party Assessments
 Due Diligence: Assess vendors’ compliance with PDPL before engagement and conduct
annual reviews thereafter.
 Contractual Safeguards: Ensure vendor agreements include:
o Confidentiality and data protection obligations.
o Breach notification timelines.
o Audit rights for data protection measures.
 Audits: Perform detailed audits of vendors every two years.
9. Data Retention and Deletion Policies
 Retention Periods:
o Employee records: Retain for five years post-employment.
o Customer data: Retain during the contractual relationship and up to three years
post-termination.
o Sensitive data: Retain only for the shortest period necessary.
 Secure Deletion: Implement automated systems for secure deletion of expired data and
maintain an audit trail.
10. Technology and Security Enhancements

 Encryption Standards: Encrypt personal data both in transit and at rest using industry-
standard protocols.
o Update encryption keys annually.
 Access Control: Implement role-based access controls to restrict data access to
authorized personnel.
 Regular Testing: Conduct monthly security patches and annual penetration tests to
identify vulnerabilities.
11. Audit and Compliance Monitoring
 Internal Audits: Perform quarterly internal audits to assess compliance with PDPL.
 External Audits: Engage third-party auditors annually to ensure robust compliance.
 Reporting: Submit audit findings to senior management and address identified gaps
within 30 days.

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Introduction

1. Access the SDAIA registration platform.

2. Data Processing Records

4. Privacy Notices and Consent Management

 Transparency: Ensure privacy notices include:

5. Cross-Border Data Transfers

o Maintain detailed records of all cross-border transfers, including recipient details

 Annual Review: Conduct annual audits of cross-border data transfer arrangements.

 Obligation: Facilitate the exercise of data subject rights, including:

1. Develop clear procedures for handling data subject requests.

 Tracking: Maintain logs of all requests and actions taken.

7. Data Breach Response Plan

 Notification Timeline: Notify SDAIA within 72 hours of becoming aware of a breach.

8. Vendor and Third-Party Assessments

9. Data Retention and Deletion Policies

10. Technology and Security Enhancements

11. Audit and Compliance Monitoring

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