United Arab Emirates (UAE) PDPL Execution: Six Steps to Comply with PDPL
The UAE Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data (PDPL) establishes a robust framework for data privacy. Organizations must implement key measures to ensure compliance and protect personal data effectively.
1) Conduct PIA/DPIA/TIA (Risk Assessments)
Organizations should perform Privacy Impact Assessments (PIA), Data Protection Impact Assessments (DPIA), and Transfer Impact Assessments (TIA) to identify applications and business processes handling Personally Identifiable Information (PII). These assessments ensure compliance with data-sharing requirements, particularly for data transferred outside the UAE.
Decree: Article 21, 22, and 23
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2) Discover PII (Personal Data Bill of Materials)
To maintain a structured data governance approach, organizations must:
- Conduct data discovery and data mapping
- Build a Data Bill of Materials (DBoM)
- Maintain a Record of Processing Activities (RoPA)
Regular audits and reviews should be conducted to evaluate compliance and data security.
Decree: Article 7 and 8
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3) Implement Data Subject Rights Management0
Organizations should establish a secure portal that enables Data Subjects to exercise their rights, such as:
- Right to Receive Information
- Right to Request Transfer of Personal Data
- Right to Stop Processing
Privacy teams must be equipped to manage and fulfill these requests efficiently using data discovery modules.
Decree: Article 13, 14, 15, 16, 17, and 18
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4) Establish a Centralized Consent Management System
A centralized system should be implemented to manage:
- Consent collection, storage, and withdrawal
- Privacy notice and preference management (including digital marketing consent) for Data Subjects
Decree: Article 6
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5) Enforce Storage Limitation Requirements
Organizations must establish storage limitation policies by regularly reviewing personal data holdings and ensuring that data is erased or anonymized when no longer required.
Decree: Article 7
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6) Implement Data Disclosure and Data Breach Management and Notification
Organizations must automate their internal breach management and external notification processes to respond within stipulated timeframes. This includes enabling systems and workflows for notifying affected Data Subjects and the Bureau without delay.
Decree: Article 9
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Conclusion
The UAE’s PDPL sets forth a comprehensive approach to data privacy and protection. By implementing risk assessments, data discovery, consent management, and breach response mechanisms, organizations can ensure compliance while fostering trust among Data Subjects. Proactively adhering to these regulations not only mitigates risks but also strengthens data security and governance frameworks in the evolving digital landscape.