Egypt's Personal Data Protection Law (PDPL)
The Trust Challenge

Key obligations and consequences

  • Article 1 states that the Law solely applies to personal data that has been electronically processed, whether partially or entirely, hence data held exclusively in a physical format is not regulated.
  • Article 3 outlines a number of important exceptions to the Law, such as where the data is processed by a natural person for personal use, where it is used for informational purposes provided it is true and accurate and used only for that purpose or the personal data is held by the Central Bank of Egypt or any of the entities subject to its purview.

Under Article 4

  • Collect Personal Data with the Data Subject’s consent or legal basis.
  • Ensure data is accurate, sufficient, and relevant to its purpose.
  • Define processing methods unless delegated in writing to a Processor.
  • Ensure data is collected only for a specific, valid purpose.
  • Do not disclose data unless legally allowed.
  • Apply technical and legal safeguards to protect data and ensure confidentiality.
  • Delete data after its purpose is fulfilled, or anonymize if retained legally.
  • Correct data errors immediately when known.
  • Keep records of data categories, disclosures, retention, deletion, and security measures.
  • Obtain a license/permit from the Data Protection Center.
  • Appoint a local representative if based outside Egypt.
  • Demonstrate compliance and allow inspections by the Center.

Each Controller is individually responsible, and Data Subjects may exercise their rights with any Controller.

Under Article 5

  • Process data as per the law, based on written instructions from the Center, Controller, or relevant parties.
  • Ensure the purpose is lawful and does not violate public order or morals.
  • Limit Processing to the intended purpose and duration; notify relevant parties of the timeframe.
  • Delete or return data after Processing ends.
  • Do not disclose data or results unless legally permitted.
  • Avoid Processing that conflicts with the Controller's purpose, unless for non-profit statistical/educational use.
  • Secure Processing activities, systems, and data.
  • Avoid harming Data Subjects.
  • Maintain a Processing record detailing scope, contact info, duration, security measures, and more.
  • Demonstrate compliance when requested and allow inspections by the Center.
  • Obtain a license/permit from the Center.
  • Appoint a local representative if based outside Egypt.

Each Processor must comply unless roles and responsibilities are clearly defined by agreement.

Under Article 7

Each of the Controller and the Processor, as the case may be, shall notify the Center with any Personal Data Infringement, within seventy-two (72) hours of such infringement. In the event that such infringement relates to national security protection concerns, the notification shall be immediate. In all events, the Center shall immediately notify the National Security Authorities with the infringement and provide them, within seventy-two (72) hours from being aware of the Infringement, with the following:

  • description of the nature of the infringement, the form and the reasons thereof as well as the approximate number of Personal Data and their records;
  • the information of the Data Protection Officer;
  • the potential consequences of the infringement;
  • description of the procedures which have been followed and the proposed procedures to be adopted in order to minimize the negative impacts of the infringement;
  • evidence of documenting any Personal Data Infringement and the corrective actions which have been taken to solve the same and;
  • any documents, information or data requested by the Center.

In all events, Controller and Processor, as the case may be, shall notify the Data Subject within three (3) days from the date of notifying the Center, with the infringement and the adopted procedures related thereto.

The Trust Challenge

Key Challenges in brief

The Data Subjects shall have the following rights:

1) to know, review and access/ obtain his/her own Personal Data, which is in possession of any Holder, Controller or Processor;

2) to withdraw the prior consent concerning the retention or Processing of his/her Personal Data;

3) to correct, edit, delete, add or update his/her Personal Data;

4) to limit the Processing to a specified purpose;

5) to be notified with any infringement to his/her Personal Data and;

6) to object to the Processing of Personal Data or its results whenever the same contradicts the Data Subject’s fundamental rights and freedom.

Under Article 14
Transfer of Personal Data which is collected or prepared for Processing, to a foreign country, or its storage or sharing may only be undertaken if the level of data protection or security in the foreign country meets (or exceeds) the requirements stipulated under this Law, and subject to obtaining a relevant License or Permit from the Center.

Under Article 8
1) The Center shall set a register for the information of Data Protection Officers. The Executive Regulations shall determine the conditions, procedures and mechanisms of registration.

2) The legal representative of the juristic person, with respect to any Controller or Processor, shall appoint a competent employee to be responsible for the protection of Personal Data, inside its legal entity and among its personnel structure. Said employee shall be registered in the register designated for the Data Protection Officers at the Center and such appointment shall be announced.

3) Controller or Processor who is a natural person, shall be the one in-charge of the application of the provisions of this Law.

Under Article 2
Personal Data may not be collected, Processed, disclosed, or revealed by any means except with the explicit consent of the Data Subject or where otherwise permitted by law.

Under Article 4
After obtaining the Data Subject’s consent or where otherwise permitted by law Personal Data could be obtained or received from the Holder or the competent entities providing such data, as applicable.

Under Article 6
Consent of the Data Subject required for electronic processing to be considered legitimate and legal, provided it was given for achieving a specific purpose.

Under Article 12
With exception to the cases authorized by law, Controller or Processor must obtain the explicit written consent of the Data Subject.

Under Article 17
Setting clear and uncomplicated mechanisms to allow the Data Subject to opt-out or withdraw his/her consent in relation thereto.

1) Notify the center: Within 72 hours by Controller/Processor. Immediate notification if national security is involved.

2) Notify to Data Subject: Within 3 days after notifying the Center. Include details of the breach and actions taken.

3) Automate breach detection and response processes.

4) Notify national security authorities immediately if the breach has national security implications.

Under Article 3
1) Personal Data shall be collected for legitimate, specific, and transparent purposes to the Data Subject.

2) Personal Data shall be correct, valid, and secured.

3) Personal Data shall be processed in a legitimate manner and in compliance with the purposes for which it is being collected.

4) Personal Data shall not be retained for a period longer than that is necessary for the fulfilment of the purpose thereof.

Win-Win Situation

Solutions

TurtleShield PA (Privacy Automation) automates and streamline privacy-related processes and tasks. PIAs and DPIAs aim to enhance privacy practices, ensure compliance with applicable privacy laws and regulations, and protect sensitive information. Overall, a privacy automation solution simplifies and streamlines privacy management processes, reducing the risk of non-compliance and improving data protection practices.

Our AI-based, patented solution, TurtleShield PI (Privacy Intelligence) discovers all personal and sensitive data in structured and unstructured data systems across on-premises and multi-cloud environments. TurtleShield DI (Data Inventory) enables organizations to inventory & map their entire “Data footprint”, enabling them to protect what matters the most.

Often there are silos within entities or business and IT teams and it is challenging to get a full picture of data going outside organization and which is coming into organization, especially when data is shared with third parties, vendors, business partners and much more. Our TurtleShield PI (Privacy Intelligence) creates a data map based on your “data sharing”, to facilitate you to take action on it.

TurtleShield DM (Data Minimization) helps businesses minimize excess data and adhere to data minimization principle. This is data hygiene control and we are approaching it from a risk reduction and compliance perspective. We scan large data sets to scan for excess data using Machine Learning and find out excess data including personal data. This can eliminate operational inefficiencies and save cost by removing the unwanted data and legal cost of having it with respect to regulatory compliance.

TurtleShield (Right to Erasure) provides the businesses the capabilities to comply with mandatory deletion of personal data by providing the capabilities to delete the data on request along with the validation of the deletion.

Search capability in large datasets to fulfill data subject requests in totality and at rapid space. Assumption that data only exists in databases and nowhere else is often not reality as customer data exists in many sources. Using Machine learning and AI we crawl across data sources and predict where PII can exist.

TurtleShield CM (Consent Management) is the solution designed to help in enabling consent compliance within your organization involves implementing processes, technologies, and policies that ensure you collect and manage user consent in a way that aligns with applicable data protection regulations and industry best practices. It also helps in enabling consent management in 22 regional languages.

TurtleShield DBM (Data Breach Management) helps organizations efficiently verify, assess, contain, manage and respond to data breaches including notifying affected individuals and regulatory bodies as per the legal requirements. TurtleShield DBM streamlines data breach management process, handles stakeholder management, accelerates breach response, enabling organizations to notify regulators and stakeholders within the required timeframe.

The Trust Challenge

Key obligations and consequences

Pointer

Applicability -
Article 3 states

  • Article 1 states that the Law solely applies to personal data that has been electronically processed, whether partially or entirely, hence data held exclusively in a physical format is not regulated.
  • Article 3 outlines a number of important exceptions to the Law, such as where the data is processed by a natural person for personal use, where it is used for informational purposes provided it is true and accurate and used only for that purpose or the personal data is held by the Central Bank of Egypt or any of the entities subject to its purview.
Pointer

Data Controller Obligations -
Under Article 4

  • Collect Personal Data with the Data Subject’s consent or legal basis.
  • Ensure data is accurate, sufficient, and relevant to its purpose.
  • Define processing methods unless delegated in writing to a Processor.
  • Ensure data is collected only for a specific, valid purpose.
  • Do not disclose data unless legally allowed.
  • Apply technical and legal safeguards to protect data and ensure confidentiality.
  • Delete data after its purpose is fulfilled, or anonymize if retained legally.
  • Correct data errors immediately when known.
  • Keep records of data categories, disclosures, retention, deletion, and security measures.
  • Obtain a license/permit from the Data Protection Center.
  • Appoint a local representative if based outside Egypt.
  • Demonstrate compliance and allow inspections by the Center.

Each Controller is individually responsible, and Data Subjects may exercise their rights with any Controller.

Pointer

Data Processor Obligations -
Under Article 5

  • Process data as per the law, based on written instructions from the Center, Controller, or relevant parties.
  • Ensure the purpose is lawful and does not violate public order or morals.
  • Limit Processing to the intended purpose and duration; notify relevant parties of the timeframe.
  • Delete or return data after Processing ends.
  • Do not disclose data or results unless legally permitted.
  • Avoid Processing that conflicts with the Controller's purpose, unless for non-profit statistical/educational use.
  • Secure Processing activities, systems, and data.
  • Avoid harming Data Subjects.
  • Maintain a Processing record detailing scope, contact info, duration, security measures, and more.
  • Demonstrate compliance when requested and allow inspections by the Center.
  • Obtain a license/permit from the Center.
  • Appoint a local representative if based outside Egypt.

Each Processor must comply unless roles and responsibilities are clearly defined by agreement.

Pointer

Obligation to Notify and Inform -
Under Article 7

  • description of the nature of the infringement, the form and the reasons thereof as well as the approximate number of Personal Data and their records;
  • the information of the Data Protection Officer;
  • the potential consequences of the infringement;
  • description of the procedures which have been followed and the proposed procedures to be adopted in order to minimize the negative impacts of the infringement;
  • evidence of documenting any Personal Data Infringement and the corrective actions which have been taken to solve the same and;
  • any documents, information or data requested by the Center.

In all events, Controller and Processor, as the case may be, shall notify the Data Subject within three (3) days from the date of notifying the Center, with the infringement and the adopted procedures related thereto.

The Trust Challenge

Key Challenges in brief

Pointer

Data Subject Rights
The Data Subjects shall have the following rights:

1) to know, review and access/ obtain his/her own Personal Data, which is in possession of any Holder, Controller or Processor;

2) to withdraw the prior consent concerning the retention or Processing of his/her Personal Data;

3) to correct, edit, delete, add or update his/her Personal Data;

4) to limit the Processing to a specified purpose;

5) to be notified with any infringement to his/her Personal Data and;

6) to object to the Processing of Personal Data or its results whenever the same contradicts the Data Subject’s fundamental rights and freedom.

Pointer

Cross-Border Personal Data Transfer
Under Article 14

Transfer of Personal Data which is collected or prepared for Processing, to a foreign country, or its storage or sharing may only be undertaken if the level of data protection or security in the foreign country meets (or exceeds) the requirements stipulated under this Law, and subject to obtaining a relevant License or Permit from the Center.

Pointer

Data Protection Officer Appointment
Under Article 8

1) The Center shall set a register for the information of Data Protection Officers. The Executive Regulations shall determine the conditions, procedures and mechanisms of registration.

2) The legal representative of the juristic person, with respect to any Controller or Processor, shall appoint a competent employee to be responsible for the protection of Personal Data, inside its legal entity and among its personnel structure. Said employee shall be registered in the register designated for the Data Protection Officers at the Center and such appointment shall be announced.

3) Controller or Processor who is a natural person, shall be the one in-charge of the application of the provisions of this Law.

Pointer

Consent Management

Under Article 2
Personal Data may not be collected, Processed, disclosed, or revealed by any means except with the explicit consent of the Data Subject or where otherwise permitted by law.

Under Article 4
After obtaining the Data Subject’s consent or where otherwise permitted by law Personal Data could be obtained or received from the Holder or the competent entities providing such data, as applicable.

Under Article 6
Consent of the Data Subject required for electronic processing to be considered legitimate and legal, provided it was given for achieving a specific purpose.

Under Article 12
With exception to the cases authorized by law, Controller or Processor must obtain the explicit written consent of the Data Subject.

Under Article 17
Setting clear and uncomplicated mechanisms to allow the Data Subject to opt-out or withdraw his/her consent in relation thereto.

Pointer

Data Breach notification

1) Notify the center: Within 72 hours by Controller/Processor. Immediate notification if national security is involved.

2) Notify to Data Subject: Within 3 days after notifying the Center. Include details of the breach and actions taken.

3) Automate breach detection and response processes.

4) Notify national security authorities immediately if the breach has national security implications.

Pointer

Data Collection and Processing
Under Article 3

1) Personal Data shall be collected for legitimate, specific, and transparent purposes to the Data Subject.

2) Personal Data shall be correct, valid, and secured.

3) Personal Data shall be processed in a legitimate manner and in compliance with the purposes for which it is being collected.

4) Personal Data shall not be retained for a period longer than that is necessary for the fulfilment of the purpose thereof.

Win-Win Situation

Solutions

Pointer

Privacy Process Automation: TurtleShield PA (Privacy Automation) automates and streamline privacy-related processes and tasks. PIAs and DPIAs aim to enhance privacy practices, ensure compliance with applicable privacy laws and regulations, and protect sensitive information. Overall, a privacy automation solution simplifies and streamlines privacy management processes, reducing the risk of non-compliance and improving data protection practices.

Pointer

Data discovery, inventory and mapping: Our AI-based, patented solution, TurtleShield PI (Privacy Intelligence) discovers all personal and sensitive data in structured and unstructured data systems across on-premises and multi-cloud environments. TurtleShield DI (Data Inventory) enables organizations to inventory & map their entire “Data footprint”, enabling them to protect what matters the most.

Pointer

Third party Privacy Intelligence (monitors third party sharing): Often there are silos within entities or business and IT teams and it is challenging to get a full picture of data going outside organization and which is coming into organization, especially when data is shared with third parties, vendors, business partners and much more. Our TurtleShield PI (Privacy Intelligence) creates a data map based on your “data sharing”, to facilitate you to take action on it.

Pointer

Data Minimization: TurtleShield DM (Data Minimization) helps businesses minimize excess data and adhere to data minimization principle. This is data hygiene control and we are approaching it from a risk reduction and compliance perspective. We scan large data sets to scan for excess data using Machine Learning and find out excess data including personal data. This can eliminate operational inefficiencies and save cost by removing the unwanted data and legal cost of having it with respect to regulatory compliance.

Pointer

Right to Erasure with Assured Deletion: TurtleShield (Right to Erasure) provides the businesses the capabilities to comply with mandatory deletion of personal data by providing the capabilities to delete the data on request along with the validation of the deletion.

Pointer

Enable Data subject rights with cost savings and compliance in totality: Search capability in large datasets to fulfill data subject requests in totality and at rapid space. Assumption that data only exists in databases and nowhere else is often not reality as customer data exists in many sources. Using Machine learning and AI we crawl across data sources and predict where PII can exist.

Pointer

Consent Management: TurtleShield CM (Consent Management) is the solution designed to help in enabling consent compliance within your organization involves implementing processes, technologies, and policies that ensure you collect and manage user consent in a way that aligns with applicable data protection regulations and industry best practices. It also helps in enabling consent management in 22 regional languages.

Pointer

Data Breach Management: TurtleShield DBM (Data Breach Management) helps organizations efficiently verify, assess, contain, manage and respond to data breaches including notifying affected individuals and regulatory bodies as per the legal requirements. TurtleShield DBM streamlines data breach management process, handles stakeholder management, accelerates breach response, enabling organizations to notify regulators and stakeholders within the required timeframe.

Featured News, Blogs

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