Understanding Saudi Arabia’s Personal Data Protection Law (PDPL)

Saudi Arabia’s Personal Data Protection Law (PDPL) sets mandatory rules for how organizations collect, use, store, share and transfer personal data. It establishes individual rights and clear accountability for data controllers and processors.

For CISOs, compliance managers and IT leaders operating in Saudi Arabia, PDPL offers a pragmatic blueprint to reduce privacy risk, demonstrate due diligence and earn trust from customers, employees and regulators. With stronger enforcement and rising expectations from partners and auditors, operationalizing PDPL should be a core business objective.

Although inspired by global privacy standards, PDPL is not a carbon copy of the GDPR. The structure and core ideas feel familiar, for example the controller–processor model, individual rights, purpose limitation and security requirements. PDPL is more prescriptive in certain areas, such as breach reporting timelines and transfer restrictions, and it contains local nuances on governmental access, residency, and consent conditions. For teams already working with GDPR, PDPL will feel recognizable but requires its own operational interpretation.

This guide translates PDPL into practical actions. It covers scope, roles, legal bases, principles, rights, governance, security, third parties and enforcement.

Read also: PDPL vs GDPR comparison

Overview: objectives and principles

The scope of the PDPL is structured around the following core concepts that apply across  industries and technology stacks:

• Roles and responsibilities
• Legal bases and processing principles
• Data subject rights
• Governance and documentation
• Security and breach handling
• International transfers
• Oversight and sanctions

The law’s objectives are clear. It:

• Gives individuals meaningful control over their personal data
• Mandates fair and transparent processing tied to legitimate purposes
• Limits collection and retention
• Requires appropriate security
• And clarifies how accountability is allocated between data controllers and processors 

Regulators are empowered to investigate and penalize violations based on the principle of evidence-based compliance.

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Scope, definitions and roles

PDPL applies to any processing of personal data in Saudi Arabia and to certain processing outside the Kingdom that targets individuals inside it. Public bodies, private companies, non-profits and foreign entities can all be in scope. Purely personal or household activities that do not involve publication or broad disclosure are out of scope.

Personal data covers any information that directly or indirectly identifies individuals. Beyond obvious identifiers (names, national IDs, contact details), PDPL includes device identifiers, precise location and combined datasets where individuals can reasonably be identified. Data that has been irreversibly anonymized falls outside PDPL.

The law distinguishes controllers (who determine the purposes and means of processing) from processors (who process on behalf of controllers). Controllers carry primary accountability. Processors must follow documented instructions and are prohibited from using data for their own purposes. Role assignment often varies by processing activity.

Even with a limited local presence, the PDPL offers a strong benchmark for privacy governance. For organisations operating in Saudi Arabia, harmonizing PDPL controls will improve audit readiness and accelerate partner due diligence. This will be notably beneficial if the organisation already aligns with the GDPR or ISO/IEC 27701.

Lawful basis and consent

Each processing activity should rest on a lawful basis. Common grounds include explicit consent, performance of a contract, compliance with a legal obligation, protection of vital interests and legitimate interests that do not override individuals’ rights. Organizations should map every processing activity to one lawful basis and record the rationale.

Consent under PDPL must be explicit, specific and informed. Pre‑ticked boxes or silence are not valid. Individuals must be able to withdraw consent easily; once withdrawn, consent-dependant processing should stop unless another lawful basis applies.

Processing principles in practice

Processing under the PDPL is expected to be fair and transparent, tied to clear and legitimate purposes and limited to what is necessary.

Data accuracy requirements mean records should be properly maintained and up-to-date. The law also imposes storage limitations.

Deletion or anonymization is required when purposes are fulfilled, unless a law mandates longer retention.

Data-security measures are expected to be appropriate to the nature, volume and risks of processing.

In practice, the law requires data collection purposes to be defined at a practical level. This can be achieved, for example, by standardizing forms and configuring APIs to minimize fields collected. Analytics can be structured with privacy-by-default configurations. Retention schedules should align closely to legal and business needs.

These approaches benefit organizations by reducing risk, improving data quality and simplifying audits.

Data subject rights and handling

Individuals have the right to be informed about processing, to access their data and to correct inaccuracies. They may request deletion in defined situations, such as when data is no longer needed, was collected unlawfully or where consent has been withdrawn and no other lawful basis applies. If retention is required by law or needed to establish or defend legal claims, the reasoning and scope should be documented.

PDPL also supports objections to certain processing, particularly direct marketing. Individuals can request restriction of processing, which typically means retaining but not actively using data while a dispute is assessed. Organizations should operate a clear intake, verification, routing and fulfillment process with auditable timelines and outcomes.

Governance, documentation and accountability

Senior management are expected to assign roles and responsibilities for data protection, provide resources and support training. In many cases it will be necessary to appoint a data protection officer (or equivalent) to advise on compliance, monitor practices and liaise with the authority.

DPOs can be expected to maintain records of processing activities (RoPA) describing data categories, purposes, data subjects, recipients, transfers, retention periods and security measures.

For processing likely to result in high risk to individuals, DPOs would be expected to conduct data protection impact assessments (DPIAs) to analyze necessity, proportionality, risks and mitigations. Internal audits should verify that practices match policy and documentation.

Security, incident response and breach notification

PDPL requires appropriate technical and organizational measures proportional to risk.

Common technical controls include:

• Encryption
• access control
• logging and monitoring
• network segmentation
• secure development practices.

Organizational controls include:

•  role-based access
• segregation of duties
• supplier risk management
• targeted awareness

Personal data breaches resulting in loss, alteration, unauthorized disclosure or access demand structured responses. Incident management plans should cover detection, containment, investigation, remediation and notification. The competent authorities should be notified immediately when harm to individuals is likely. Affected individuals should also be notified without delay when they may need to take protective action if they are affected by a data breach. Processors should inform controllers of incidents without undue delay.

International transfers and third parties

The PDPL restricts transfers of personal data outside Saudi Arabia unless protection remains comparable. Some transfers rely on adequacy decisions, while others require contractual safeguards or binding internal rules. In certain cases, explicit consent can be used.

Compliance with the law requires an assessment of the destination’s legal and practical environment. Safeguards should be documented and reviewed periodically.

Controller–processor contracts should specify subject matter, duration, nature, purpose, data types, confidentiality, security, sub‑processing conditions, audit rights and end-of-contract data return or deletion. There should be a clear and transparent legal basis for sharing data with other controllers.

The responsibilities for rights handling and security should be defined and current data maps and contract inventories should not be shared.

Oversight, enforcement and sanctions

A competent supervisory authority issues regulations and guidance, conducts inspections, requests information and reviews documentation. Organizations should track updates to both the primary law and implementing regulations and adjust practices accordingly. Transparent, timely communication and evidence of good-faith compliance can reduce the likelihood of penalties in cases where the law has not been followed correctly.

Sanctions range from corrective orders to administrative fines. Factors include the nature and severity of violations, duration, number of affected individuals and prior history. Violations of the law can also result in reputational and operational costs. 

How to implement PDPL in your organization

A structured, risk-based approach lets small and mid-sized teams operationalize PDPL efficiently and build audit-ready evidence as they go.

Scope and map

Identify all processing activities, systems and vendors that handle personal data of individuals in Saudi Arabia. For each activity, record the controller or processor role, purpose, legal basis, data types, recipients, transfers and retention rules. This becomes the backbone of your RoPA and makes high-risk processing visible, including areas that may need a DPIA.

Assess and prioritize

Check your notices, consent flows, rights handling, security measures, incident response and transfer mechanisms against PDPL requirements. Prioritize remediation based on risk. Activities involving sensitive data, high volumes, user-facing systems or complex vendor chains should move first. Update privacy notices and correct consent capture and withdrawal paths.

Operationalize and evidence

Roll out the required controls, finalize controller and processor terms, run role-based training and put DSAR and breach response playbooks into daily use. Automate retention and deletion where possible. Capture evidence as you go, for example policies, assessments, consents, training logs, system configurations, test results and decision records. This supports internal audits and regulator inquiries.

Cyberday can streamline these steps with PDPL-ready tasks and controls, RoPA/DPIA templates, role-based workflows and centralized evidence collection. It also maps PDPL work to other frameworks to reduce duplicate effort and speed up reporting.

Continuous improvement and measuring progress

PDPL compliance is an operating cadence, not a one-off project. This means owners should be assigned, review cycles set and dashboards used to monitor risks, control health and outcomes. Management reviews should assess incidents, audit findings, risk posture and improvement opportunities at planned intervals.

Useful metrics to monitor include:

• DSAR volumes, SLA adherence and satisfaction
• Time from breach detection to decision and to notification
• RoPA completeness and review cadence
• DPIA coverage for high-risk activities and mitigation progress
• Training completion and assessment scores by role
• Transfer assessments by destination and safeguard type
• Vendor risk ratings and remediation status
• Deletion success rates against retention schedules

Cyberday supports continuous improvement with automated reminders, control-status dashboards and multi-framework mapping. Centralized evidence simplifies internal reporting and external assessments.

Why PDPL matters for cyber resilience and compliance

Operationalizing PDPL clarifies what personal data you hold, where it flows and who can access it. That clarity reduces breach likelihood and impact, speeds incident response and limits data sprawl through minimization and retention discipline.

From a business perspective, PDPL maturity accelerates partner onboarding, shortens security and privacy reviews and strengthens regulator confidence for companies with operations in the Kingdom. It improves data quality by removing duplicates and stale records and provides a defensible narrative when incidents occur. The PDPL can be treated as a core element of organizational security and privacy operating models.

FAQs

Is PDPL the same as GDPR?

They share core concepts, such as their lawful bases, principles, rights, accountability and transfer restrictions, but they are not identical. Organisations operating in Saudi Arabia should align their program to the PDPL’s definitions and local regulator guidance rather than copying GDPR templates.

Do we need a data protection officer?

PDPL expects clear accountability. Many organizations will appoint a DPO or equivalent as a result. Base the decision to hire a DOP on processing scale and risk; high‑risk activities make a dedicated role more necessary.

How long can we retain personal data?

Only as long as necessary for the stated purposes or as required by law. Define dataset-level retention schedules, automate deletion where possible and document exceptions such as legal holds.

When is a DPIA required?

When processing is likely to pose high risk to individuals. This can include activities such as large-scale processing of sensitive data, systematic monitoring or combining datasets that materially increase risk. DPIAs should be used before a launch or implementing significant organizational changes.

Do we have to notify every breach?

No. The authority, and sometimes affected individuals, should only be notified when harm is likely. Criteria and decision workflows should be defined in your incident plan to ensure you act quickly and consistently.

How should we manage foreign cloud providers?

Verify data locations, access paths, transfer safeguards and incident obligations. Ensure contracts enable rights fulfillment and secure deletion, and keep a documented assessment of destination country conditions.

Operationalize PDPL with less effort

If you’re building or maturing your PDPL program, Cyberday helps you move faster with fewer spreadsheets. Use ready-to-run PDPL controls, RoPA/DPIA templates, DSAR and breach workflows and centralized evidence to stay audit-ready while reducing manual overhead. Map once and reuse across multiple frameworks to save time.