Kingdom of Saudi Arabia's (KSA) Execution: Six Steps to Comply with PDPL

Sameer Ahirrao -

Saudi Arabia's Personal Data Privacy Protection Law (PDPL) sets requirements for data privacy and protection. Organizations must align their data protection practices with these mandates through structured execution strategies, including risk assessments, data discovery, rights management, consent management, storage limitations, and breach notification. Below is a step-by-step compliance guide aligned with the KSA PDPL.

1. Conduct Privacy, Data Protection, and Transfer Impact Assessments (PIA/DPIA/TIA)

To ensure compliance with data-sharing requirements outside KSA, organizations must conduct Privacy Impact Assessments (PIA), Data Protection Impact Assessments (DPIA), and Transfer Impact Assessments (TIA). These assessments help identify applications and business processes handling personally identifiable information (PII).

Key Actions:

  • Identify PII and Applications: Map out business processes handling PII.
  • Assess Risks: Evaluate risks associated with data processing and transfers.
  • Ensure Compliance: Align with PDPL Laws (Articles 22, 29) and Regulations (Articles 16, 25, 32).

Ardent Solution: The TurtleShield PA (Privacy Automation) automates and streamlines privacy-related processes and tasks. Conducting PIAs, DPIAs and TIAs enhances privacy practices, ensures compliance with applicable privacy laws, and also protects sensitive information.

2. Discover PII and Build a Data Bill of Materials (DBoM)

Data discovery and mapping provide clarity on the personal data that the organization holds. By building a Data Bill of Materials (DBoM) and maintaining a Record of Processing Activities (RoPA), organizations can improve transparency and compliance.

Key Actions:

  • Perform Data Discovery: Use automated tools to locate and classify PII.
  • Create a DBoM: Document data elements linked to Data Subjects.
  • Maintain RoPA: Maintain a clear record of processing activities.
  • Comply with Law (Articles 31, 33) and Regulations (Articles 18, 20, 21, 30, 32, 33).

Ardent Solution: Our Innovative tool "TurtleShield DD (Data Discovery)" addresses these challenges by discovering hard-to-find datasets at scale, enabling quick actions, and reducing compliance costs. It locates and categorizes data based on regulatory requirements in PDPL , ensuring companies maintain compliance, secure sensitive information, and minimize data breach risks.

3. Implement Data Subject Rights Management

Organizations must enable Data Subjects to exercise their rights under the PDPL, including the right to request destruction, to be informed, and to withdraw consent.

Key Actions:

  • Build a Secure Portal: Provide a user-friendly interface for Data Subjects to submit requests.
  • Enable Privacy Teams: Equip privacy teams with tools to manage and fulfill rights requests.
  • Leverage Data Discovery: Use automation to locate and process data efficiently.
  • Comply with Law (Articles 3, 4, 9, 10, 12, 13, 20, 21, 23, 24) and Regulations (Articles 3, 4, 5, 6, 7, 8, 10, 12, 13, 16, 22, 32).

Ardent Solution: TurtleShield DSAR streamlines the Data Subject Access Request (DSAR) process, ensuring efficient compliance with PDPL. With robust features and innovative tools, it helps organizations address privacy challenges effectively and efficiently.

4. Establish a Centralized Consent Management System

Consent management is crucial to PDPL compliance. Organizations must implement a centralized system to handle consent collection, storage, verification, and withdrawal.

Key Actions:

  • Centralize Consent Management: Ensure a unified system for managing individual and guardian consent.
  • Integrate Privacy Notices: Provide clear privacy notices and manage marketing preferences.
  • Comply with Law (Articles 5, 6, 7, 10, 15, 24, 25, 26) and Regulations (Articles 4, 8, 11, 12, 13, 27, 28, 29).

Ardent Solution: TurtleShield CM (Consent Management) automates required user privacy notices, the gathering and management of consent/opt-out privacy preferences, and the operational honoring of preferences by both internal and downstream third-party data sharers.

5. Enforce Storage Limitation Requirements

Organizations must implement data minimization practices, ensuring that personal data is regularly reviewed, erased, or anonymized when no longer needed.

Key Actions:

  • Establish Data Minimization Protocols: Set up automated processes for periodic data review and deletion.
  • Conduct Regular Audits: Monitor stored data for compliance.
  • Comply with Law (Articles 11, 12, 18, 31) and Regulations (Articles 7, 8, 12, 18, 31).

Ardent Solution: TurtleShield DM (Data Minimization) helps you reduce the data and focus on enterprise-centric data. It can provide you detailed insights to get rid of non-essential data, reducing cost of security and storage and building confidence of business owners and data custodians.

6. Implement Data Breach Management and Notification

Organizations must develop a structured approach for detecting, managing, and reporting data breaches to affected Data Subjects and the Competent Authority.

Key Actions:

  • Automate Breach Detection: Implement monitoring tools for real-time breach alerts.
  • Develop Notification Workflows: Ensure timely notifications to regulators and affected individuals.
  • Comply with Law (Article 20) and Regulations (Articles 24, 26, 32).

Follow PDPL Timelines for Breach Notification

To avoid penalties and ensure compliance, organizations must adhere to strict PDPL timelines for reporting breaches.

Key Requirements:

  • Notify the Competent Authority within 72 hours if an incident poses harm to Personal Data or Data Subjects.
  • Notify affected Data Subjects without undue delay if the breach may impact their data, rights, or interests.

Conclusion

Compliance with the Kingdom of Saudi Arabia’s PDPL requires a structured execution approach, covering risk assessments, data discovery, rights management, consent management, storage limitations, and breach notifications. Organizations that implement these measures effectively can achieve compliance, enhance data security, and build trust with Data Subjects and regulators in KSA.

About Ardent Privacy

Ardent’s mission is to help enterprises implement meaningful security and privacy programs aligned to their business mission, building trust and protecting data assets. Ardent’s technology “TurtleShield” is a holistic software platform that empowers enterprise security, legal, and data teams to implement and manage data privacy within the organizations with rapid data asset visibility and actions to enable privacy compliance, govern AI risk, meaningful data protection, and reduce cost of compliance and data breaches. Our unique and patented ML/AI-powered technology helps organizations comply with evolving privacy and AI regulations and accelerates adoption of AI technologies. Ardent offers a low code platform to automate Privacy & AI governance, rapid discovery of data assets and consent management with regional focus for global regulations.