Technology & Data Privacy Lawyers
We help companies comply with personal data protection rules and paper their technology arrangements.
Overview
The Personal Data Protection Law moved privacy in Saudi Arabia from optional practice to a legal obligation with a supervisory authority and consequences for breach. Any organisation collecting customer data — an app, a store, a clinic, a platform — now faces specific questions: what is the lawful basis for processing? Where is the data stored? And who has access?
We work on practical rather than cosmetic compliance: mapping actual data flows, preparing a privacy policy and terms that match what the product really does, data processing agreements with vendors, and procedures for handling data subject requests and breach incidents.
The most common error we see is a privacy policy copied from another product: elegant text that does not describe what the product does. At the first complaint or inspection, the gap between what is written and what the system does is itself the violation.
The legal framework
The Saudi digital framework combines data protection, cybersecurity and electronic transactions:
- The Personal Data Protection Law and its implementing regulations
- The supervisory authority and the controls on transfers outside the Kingdom
- The Anti-Cyber Crime Law
- The Electronic Transactions Law and electronic signatures
- The Essential Cybersecurity Controls for entities subject to them
- E-commerce and consumer protection rules for platforms
Situations we handle
Launching an app that collects user data
Before launch: the lawful basis, a clear policy, and a genuine consent mechanism rather than a tick box.
Contracting a hosting or analytics vendor
A data processing agreement allocates responsibility and governs transfers abroad. Without one the exposure sits with you alone.
A user request to delete their data
The law grants data subjects defined rights. You need a ready internal procedure, not an improvised reply to the first request.
A data breach incident
The first response determines the scale of the impact: containment, documentation, and notification as required.
Transferring data to a vendor abroad
Transfers are subject to controls. Checking them before contracting is far easier than changing the architecture later.
Costly mistakes we see
- 1
A copied privacy policy
Text that does not match the technical reality is evidence of breach, not of compliance. The policy is written after the data flow is mapped.
- 2
Consent that is not genuine
Consent buried in long terms, or made a condition of service, may not stand as a lawful basis for processing.
- 3
Collecting more data than needed
Every extra field is extra liability. Collect what the stated purpose actually requires, not what you might want one day.
- 4
No agreement with the processor
Using an external vendor without a processing agreement leaves the full regulatory exposure with you when an incident occurs.
How the procedure runs, step by step
The Personal Data Protection Law is now fully in force, and its obligations fall not only on technology companies but on every entity that processes customer or employee data.
- 1
Inventory the data and map the processing
We record what you collect: which data, from where, for what purpose, where it is stored, and who can reach it. Compliance is impossible before the inventory exists, and most entities discover processing here with no legal basis at all.
- 2
Establish the legal basis for each purpose
Every processing purpose needs a basis: consent, performance of a contract, or legitimate interest within its conditions. Relying on a blanket consent buried in terms of use is not sufficient for sensitive data.
- 3
Update policies and documentation
The privacy policy, the record of processing activities, collection notices, and data processing agreements with vendors. A policy copied from a foreign website does not meet the Saudi requirements, particularly on transfers.
- 4
Transfers outside the Kingdom
Transfer abroad is restricted by conditions, controls and an impact assessment. Using a cloud service with offshore data centres without an assessment is the most common breach and the least noticed.
- 5
Incident response and data subject rights
We build a breach notification procedure within the statutory window, and a procedure for handling access, correction and deletion requests. A late incident response multiplies both the fine and the reputational damage.
Documents we will ask you for
- A list of systems and applications that process data
- The current privacy policy and terms of use
- Service provider and hosting contracts
- The cybersecurity procedures in place
- Records of any earlier breach
- The structure of teams with data access and their permissions
Fees and timelines
We offer a compliance package at a fixed fee: data flow review, privacy policy and terms of use, and processing agreement templates. Periodic reviews and incident response are priced separately.
On timing: the core compliance package takes one to three weeks depending on the product's complexity and the number of vendors. Breach response is immediate — we work in hours, not days.
Common questions
Does the law apply to our company?
It applies broadly to the processing of personal data and is not limited to technology companies. Any organisation collecting customer or employee data falls within scope, and the exemptions are narrow and specific.
What is the lawful basis for processing?
Consent is one basis among several; others include performing a contract, a legal obligation, or legitimate interests depending on the case. Identifying the right basis for each processing activity is the core of practical compliance.
Can we transfer data outside the Kingdom?
Transfers are possible within controls relating to purpose, the level of protection at the recipient, and the safeguards adopted. This should be checked before selecting a hosting provider, not after the system is built on it.
What do we do in a data breach?
Contain the incident first, then document precisely what happened and assess the impact, then notify in accordance with the requirements and inform affected individuals where required. Improvising in the first hours is usually what multiplies the damage.
Do we need a data protection officer?
Some organisations are required to appoint one depending on the nature and scale of processing. Even where it is not mandatory, naming an internal owner is what makes responding to requests and incidents possible at all.
What rights do data subjects have?
They include being informed, access, and requesting correction or destruction in the prescribed cases. Compliance requires an internal procedure to respond within a reasonable period rather than an ad hoc reply.
Are terms of use enough?
No. Terms of use govern the contractual relationship; the privacy policy governs data processing. They are different documents with different obligations, and merging them leaves gaps in both.
Do you review the product technically?
We review data flows, documentation and contracts from a legal standpoint, and coordinate with your technical team so that what is written matches what the system actually does.
Related services
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