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Table of Contents

Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Introduction
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – First: Preparation Phase
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Second: Assessing Negative Impacts and Potential Risks of Personal Data Processing
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Third: Risk Assessment for Data Transfer or Disclosure to Entities Outside the Kingdom
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Fourth: Guidelines for Identifying Factors Related to the Analysis of Implications for the Vital Interests of the Kingdom

Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Introduction

Overview

Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Introduction provides practical direction to Controllers and other entities subject to the Saudi Personal Data Protection Law (PDPL) on how to assess and manage risks associated with cross-border personal data transfers. Issued by the Saudi Data and AI Authority (SDAIA), the guideline supports the lawful implementation of PDPL transfer provisions by explaining preparatory steps, evaluation criteria, and risk mitigation considerations when transferring or disclosing personal data outside the Kingdom of Saudi Arabia.

It complements the PDPL, its Implementing Regulations, and the Regulation on Personal Data Transfer Outside the Kingdom by introducing a structured risk-based approach and a supporting assessment tool made available through the Competent Authority’s platform.

SDAIA's Official Text

The text below reproduces official PDPL law, regulation, or guideline issued by the Saudi Data & AI Authority, verified against the original SDAIA source. No changes or reinterpretation applied.

Introduction

Given the critical role of issuing guidelines in facilitating the application of the Personal Data Protection Law (the Law), this guideline is designed to assist entities subject to the Law and support the effective implementation of its provisions. The guideline is prepared by the Saudi Data & AI Authority ("Competent Authority") with the aim of explaining the practical steps to assess the risks of transferring or disclosing personal data to entities outside the Kingdom ("Conducting Risk Assessments for Data Transfer and Disclosure). The assessment identifies preparatory steps and concepts, focusing on key measures to evaluate potential risks and negative impacts associated with the processing of personal data.

The terms and phrases contained in this guideline shall have the meanings specified before each of them in the Personal Data Protection Law issued by Royal Decree No. (M/19) dated 9/2/1443H, its amendments, and its Implementing Regulations.

Entities can utilize the supporting tool designed to assess the risks associated with personal data transfer. This tool is available on the platform of the Competent Authority and is intended to assist entities in completing this procedure.

Plain-Language Explanation

The explanation below is provided to help you understand the SDAIA’s legal text and does not replace or override the official PDPL law, regulation, or guideline.

Purpose of the Guideline

This guideline exists to support the effective application of the Personal Data Protection Law (PDPL) by translating legal transfer obligations into practical, operational steps. It helps entities understand how to evaluate risks before transferring or disclosing personal data outside the Kingdom, ensuring that transfer decisions are informed, documented, and aligned with PDPL requirements.

Issuing Authority and Regulatory Context

The guideline is issued by the Saudi Data and AI Authority (SDAIA) in its role as the Competent Authority responsible for supervising PDPL implementation. It operates alongside the Law, its Implementing Regulations, and the Regulation on Personal Data Transfer Outside the Kingdom, and should be read as supporting guidance rather than a standalone legal instrument.

Scope of Risk Assessments

The guideline focuses specifically on risks arising from the transfer or disclosure of personal data to entities located outside the Kingdom. This includes risks linked to processing activities, legal environments of recipient jurisdictions, and potential negative impacts on personal data and Data Subjects.

Preparatory Steps and Key Concepts

The guideline introduces preparatory steps that entities should undertake before conducting a risk assessment. These steps help identify relevant processing activities, understand the nature of the transfer, and frame the assessment around measurable and relevant risk factors associated with cross-border data movement.

Evaluation of Risks and Impacts

A central element of the guideline is the evaluation of potential risks and negative impacts related to the processing of personal data after transfer. This includes considering how transferred data may be accessed, used, or affected in the recipient environment, and whether such processing could undermine the level of protection required under the Law.

Use of Defined Legal Terms

All terms and phrases used within the guideline carry the same meanings as those defined in the Personal Data Protection Law (PDPL) and its Implementing Regulations. This ensures legal consistency and avoids reinterpretation or expansion beyond the statutory framework.

Supporting Risk Assessment Tool

To assist entities in completing the risk assessment process, the Competent Authority provides a dedicated supporting tool through its platform. This tool is intended to guide entities through the assessment steps, promote consistency in evaluation, and support proper documentation of transfer-related risks and decisions.

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