What Is the PDPL?
Saudi Arabia’s Personal Data Protection Law (PDPL) is the Kingdom’s comprehensive data privacy regulation, first issued by Royal Decree in September 2021 and substantially updated with implementing regulations in 2023. The PDPL governs how organizations collect, process, store, and transfer personal data of individuals within Saudi Arabia.
As of 2026, enforcement is fully active. The Saudi Data and AI Authority (SDAIA) has the mandate to investigate violations and impose penalties, which can reach up to 5 million SAR per violation, with repeat offences potentially doubling that figure.
If your business operates in Saudi Arabia or processes personal data of Saudi residents, PDPL compliance is a legal obligation — not a best practice.
Key Principles of the PDPL
The PDPL is built on several core data protection principles that should guide every aspect of your compliance programme:
- Lawful basis — Personal data must be processed based on a legitimate legal basis (consent, contractual necessity, legal obligation, vital interest, or public interest)
- Purpose limitation — Data must be collected for specific, clear, and legitimate purposes and not processed further in an incompatible manner
- Data minimization — Only collect and retain personal data that is necessary for the stated purpose
- Accuracy — Organizations must take reasonable steps to keep personal data accurate and up to date
- Storage limitation — Personal data must not be kept longer than necessary for the purpose it was collected
- Confidentiality and integrity — Appropriate technical and organizational measures must protect personal data from unauthorized access, loss, or damage
Who Is Covered?
The PDPL applies to:
- Any entity that processes personal data within Saudi Arabia
- Any entity outside Saudi Arabia that processes personal data of individuals located in Saudi Arabia
- Both private-sector companies and government entities
This extraterritorial scope means international companies serving Saudi customers or having Saudi employees must comply, even if they have no physical presence in the Kingdom.
What Qualifies as Personal Data?
The PDPL defines personal data broadly as any data that can identify an individual, directly or indirectly. This includes:
- Names, identification numbers, and contact information
- Financial and employment data
- Location data and online identifiers
- Health information (classified as sensitive personal data with additional protections)
- Biometric data
Practical Steps to PDPL Compliance
Step 1: Map Your Data Processing Activities
Create a comprehensive record of all personal data processing activities in your organization. For each activity, document:
- What personal data is collected
- The legal basis for processing
- The purpose of processing
- Where the data is stored
- Who has access
- Whether it is shared with third parties
- Retention periods
Step 2: Establish a Legal Basis for Each Processing Activity
Review every processing activity and ensure it has a valid legal basis. Consent is the most commonly relied-upon basis, but the PDPL also recognizes contractual necessity, legal obligations, and legitimate interests.
Important: Consent under the PDPL must be freely given, specific, informed, and unambiguous. Pre-ticked boxes or bundled consent are not compliant.
Step 3: Implement Privacy Notices
Provide clear, accessible privacy notices to data subjects before or at the time of data collection. Notices must include the identity of the data controller, the purposes of processing, the legal basis, data sharing recipients, transfer details, and retention periods.
Step 4: Manage Data Subject Rights
The PDPL grants individuals several rights that your organization must be prepared to fulfill:
- Right to be informed — Individuals must know how their data is processed
- Right of access — Provide copies of personal data upon request
- Right to rectification — Correct inaccurate or incomplete data
- Right to erasure — Delete personal data when no longer necessary
- Right to restrict processing — Limit processing in certain circumstances
- Right to data portability — Provide data in a structured, machine-readable format
Build internal processes and response timelines (the PDPL requires response within 30 days) to handle these requests efficiently.
Step 5: Secure Cross-Border Data Transfers
The PDPL restricts transfers of personal data outside Saudi Arabia. Transfers are permitted only when the receiving country provides an adequate level of protection, or when appropriate safeguards are in place (such as binding corporate rules or standard contractual clauses approved by SDAIA).
If you use cloud services hosted outside the Kingdom, this requirement demands careful attention.
Step 6: Implement Technical and Organizational Safeguards
Protect personal data with appropriate security measures:
- Encryption at rest and in transit
- Access controls and authentication
- Regular security assessments and penetration testing
- Data breach detection and response capabilities
- Employee training on data protection practices
Step 7: Prepare for Data Breach Notification
The PDPL requires organizations to notify SDAIA of personal data breaches that may harm data subjects. Have an incident response plan that includes detection, assessment, containment, notification, and remediation procedures.
PDPL vs. GDPR: A Quick Comparison
Many organizations familiar with the EU’s GDPR will find the PDPL conceptually similar, but there are notable differences:
- Consent requirements differ in scope and the conditions under which consent can be relied upon
- Cross-border transfer mechanisms under the PDPL are still maturing compared to GDPR’s established adequacy decisions and SCCs
- Data Protection Officer (DPO) appointment is not explicitly mandatory under the PDPL for all organizations, though SDAIA recommends it
- Penalties under the PDPL can be significant but follow a different structure than GDPR’s percentage-of-revenue model
For a detailed comparison, see our article on GDPR vs PDPL.
How SeedGovernance Helps
SeedGovernance provides a complete PDPL compliance toolkit with pre-built policy templates, data processing activity registers, consent management frameworks, and data subject request workflows. Our guided assessment helps you identify exactly where your gaps are, and our platform gives you the tools to close them systematically.
Start with our free compliance assessment to understand your current PDPL readiness.