Data Protection Officer (DPO)

What

The Personal Data Protection Law (PDPL) in Saudi Arabia may require certain organizations to appoint a Data Protection Officer (DPO). The DPO is responsible for overseeing data protection practices and ensuring compliance with the PDPL. Some entities must register their DPO with the Saudi Data & AI Authority (SDAIA).

Why it Matters

Appointing and registering a DPO demonstrates a commitment to data privacy and accountability. A qualified DPO can help your organization navigate the complexities of the PDPL, mitigate risks, and build trust.

Key Considerations

• Determine if a DPO is required, based on SDAIA guidelines (summarized below).

• Identify a qualified DPO with the necessary expertise.

• Ensure the DPO has adequate resources and independence.
  

Practical Steps

• Assess the need for a DPO based on your data processing activities.

• Appoint a DPO.

• Familiarize yourself with SDAIA's registration process and register your DPO. Official materials from SDAIA linked below:

  • Rules for Appointing Personal Data Protection Officer
    

Expanded Information on DPOs Under PDPL

The Saudi Data & Artificial Intelligence Authority (SDAIA) has published rules for appointing Personal Data Protection Officers (DPO Rules) under the Personal Data Protection Law (PDPL).

These rules outline the obligations and requirements for organizations subject to the PDPL.

Who Needs a DPO?

Controllers must appoint a DPO if they:

• are a public entity providing large-scale services involving personal data.

• conduct core activities involving regular and systematic monitoring of data subjects.

• process sensitive personal data as a core activity.
  

DPO Requirements

Controllers must ensure DPOs:

• Have relevant qualifications and experience.

• Possess knowledge of risk management and data breaches.

• Are well-versed in regulatory requirements.

A DPO can be internal or external, but they must be formally appointed in writing, and their contact details must be provided to SDAIA via the National Data Governance Platform.

Key DPO Obligations Include

• Providing support and advice on data protection.

• Conducting training and awareness activities.

• Reviewing data breach response plans.

• Preparing compliance reports.

• Staying updated with regulatory changes.
  

Official Resources for Further Reading

• Rules for Appointing Personal Data Protection Officer issued by SDAIA

• Saudi Data & AI Authority (official SDAIA website)

• The KSA’s Personal Data Protection Law (v2 April 2023)

• National Data Governance Platform