Overview
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Second: Assessing Negative Impacts and Potential Risks of Personal Data Processing establishes a structured methodology for identifying, analyzing, and measuring risks arising from personal data processing activities. This phase focuses on linking risk elements to identified processing activities, evaluating vulnerabilities, threat sources, expected events, impacts, and likelihood, and determining overall risk levels.
It further requires entities to assess the adequacy of existing controls and to implement appropriate administrative, technical, and physical safeguards in accordance with Articles 19 of the PDPL and 23 of the Implementing Regulations to reduce or mitigate identified risks prior to transferring personal data outside the Kingdom.
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.
Second: Assessing Negative Impacts and Potential Risks of Personal Data Processing Phase
This phase involves the steps required to assess the potential negative impacts and risks arising from the processing of personal data when offering a service or product to the public. The process involves the following steps:
- Linking the elements of negative impact and potential risk assessment, as outlined below, to each activity identified under Paragraph (d) of Clause (I) in this guideline. An international standard for risk assessment and threat analysis may be adopted to define these elements, taking into account the following:
The result of an analysis evaluating the adequacy of measures taken to ensure that each processing activity complies with the provisions, controls, and procedures established by the Law and its Regulations.
- Vulnerabilities or Weak Spots:
- Source of Threat: Any source, whether internal or external to the controller or processor, that engages in processing personal data for illegal purposes, whether intentionally or unintentionally.
- Expected Event: Any action that exploits existing sources of threats, vulnerabilities, or weak spots, leading to negative impacts on personal data subjects.
- Impacts: The level of damage caused by expected events which can be assessed by analyzing the extent of their impact. The impact may affect only the personal data subject, extend to their family and friends, or even reach the broader community.
- Probability of Occurrence: The likelihood of an event occurring by evaluating the resources and capabilities available to threat sources that could enable them to exploit weak spots and vulnerabilities.
- Level of Risk: The result of measuring impact severity relative to the likelihood of occurrence.
Analyzing the activities outlined in Paragraph (d) of Clause (I), involving additional elements relevant to each phase. This includes identifying elements associated with assessing the negative impacts and potential risks of processing personal data, as described in this section, and evaluating their levels. These elements include but are not limited to, analyzing the activities related to enabling the personal data subject to access their data held by the controller, which involves evaluating the measures implemented and assessing their adequacy to verify the subject's identity. Insufficient measures in this regard constitute a vulnerability that could be exploited by unauthorized individuals, potentially leading to access or misuse of the data for personal gain or harm to the data subject.
Identifying suitable controls and measures to prevent risks, minimize their likelihood, or mitigate their impact when they occur. This is achieved by implementing relevant administrative, technical, and physical controls in accordance with the provisions of Article (19) of the Law and Article (23) of its Implementing Regulation.
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.
