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Table of Contents

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Personal Data Processing Activities Records Guideline (RoPA) – Introduction
Personal Data Processing Activities Records Guideline (RoPA) – Objectives
Personal Data Processing Activities Records Guideline (RoPA) – First: Personal Data Processing Activities Records Requirements
Personal Data Processing Activities Records Guideline (RoPA) – Second: Contents of Personal Data Processing Activities Records
Personal Data Processing Activities Records Guideline (RoPA) – Third: Content Details of Personal Data Processing Activities Records

Personal Data Processing Activities Records Guideline (RoPA) – Second: Contents of Personal Data Processing Activities Records

  • This article is verified from SDAIA
  • halaprivacy.com
  • Updated: December 23, 2025
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Overview

Personal Data Processing Activities Record Guideline – Second: Contents of Personal Data Processing Activities Records specify the minimum mandatory information that Controllers must include when preparing Records of Processing Activities under the Saudi Personal Data Protection Law (PDPL).

This section defines the core data elements that ensure transparency, accountability, and regulatory oversight, covering controller details, processing purposes, data categories, retention, disclosures, cross-border transfers, and security measures.

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: Contents of Personal Data Processing Activities Records

Records of personal data processing activities shall, as a minimum, include the following:

  1. Controller's name and relevant contact details.

  2. Information of the Data Protection Officer (DPO), wherever the appointment of a DPO is required.

  3. Purposes of personal data processing.

  4. Description of the personal data categories being processed, and data subjects categories.

  5. Retention period for personal data and, where possible, specific retention periods for each category of personal data.

  6. Categories of recipient entities to whom the personal data has been or will be disclosed.

  7. Description of operations of personal data transfer outside the Kingdom, including the legal basis for the transfer and the recipient entities.

  8. Description of the procedures and organizational, administrative, and technical measures in place that ensure the security of personal data, where possible.

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.

1. Controller and Contact Information

This requirement explains that RoPA must identify the Controller by name and include relevant contact details. This ensures clear accountability and enables communication with the Competent Authority (SDAIA) and Data Subjects when necessary.

2. Personal Data Protection Officer (DPO) Details

Where a Data Protection Officer is required to be appointed, the RoPA must include the DPO’s information. This supports governance, oversight, and regulatory engagement under PDPL requirements.

3. Purposes of Processing

This requirement clarifies that Controllers must document the specific purposes for which personal data is processed. Clearly defined purposes are essential for assessing lawfulness, necessity, and proportionality.

4. Categories of Personal Data and Data Subjects

This requirement explains that RoPA must describe both the categories of personal data processed and the categories of Data Subjects concerned. This provides visibility into the scope and sensitivity of processing activities.

5. Retention Periods

This requirement clarifies that Controllers must record the retention period for personal data and, where possible, specify retention periods for each data category. This supports compliance with data minimization and destruction obligations.

6. Categories of Recipients

This requirement explains that RoPA must identify the categories of recipient entities to whom personal data has been or will be disclosed. This includes internal and external recipients and supports transparency and risk assessment.

7. Cross-Border Data Transfers

This requirement clarifies that any transfer of personal data outside the Kingdom must be documented, including the legal basis for the transfer and the recipient entities involved. This is critical for compliance with PDPL transfer restrictions.

8. Security Measures

This requirement explains that RoPA should describe the organizational, administrative, and technical measures implemented to ensure the security of personal data, where possible. This demonstrates accountability and risk mitigation.

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