Saudi Personal Data Protection Law (KSA PDPL) Article 7 establishes that consent cannot be made a condition for obtaining a service or benefit unless the processing of personal data is directly required for that service or benefit.
This ensures that consent remains voluntary and connected only to processing activities that are necessary for the service being provided.
SDAIA's Official PDPL 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.
Article 7 The consent referred to in paragraph (1) of Article (5) of this Law may not form a condition of providing a service or a benefit, unless such service or benefit is directly related to the Processing of Personal Data for which the consent is given.
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.
PDPL Article 7
Consent Cannot Be Forced
This provision states that consent cannot be required as a condition for providing a service or benefit unless the service or benefit depends directly on the processing of the personal data for which consent is sought. It ensures that individuals are not placed under pressure to agree to processing that is unrelated to the service they are attempting to use.
The text limits the use of consent as a prerequisite and ensures that only necessary data is tied to the provision of a service. This protects the voluntary nature of consent and ensures that individuals retain control over personal data that has no connection to the requested service.
Frequently Asked Questions (FAQs)
Under the Saudi Personal Data Protection Law (KSA PDPL), can a website force me to accept marketing consent to create an account?
Usually no, consent cannot be a condition for a service unless that processing is directly required to provide the service. If marketing is optional and not needed to deliver the account, tying access to marketing consent conflicts with the rule in Article 7.
Does Saudi Personal Data Protection Law (KSA PDPL) Article 7 mean I can refuse optional data collection and still use the core service?
Yes, as a rule of thumb, you should still get the service if the processing you refused is not directly related to delivering it. Article 7 is designed to keep consent voluntary and linked only to what the service truly needs.
In e-commerce KSA, can checkout be blocked unless the customer agrees to receive promotional messages?
No, not if promotional messaging is not directly needed to complete the purchase. Article 7 limits “take it or leave it” consent when the processing is unrelated to the service or benefit.
For a Saudi fintech app, can we require consent for analytics tracking as a condition to use the app?
Only if the analytics processing is directly related to providing the service or benefit. If it is not necessary for the core service, Article 7 suggests it should be optional, not forced.
In SaaS, can we bundle consent for product updates, newsletters, and third-party sharing into a single “agree to continue” button?
As a rule of thumb, you should not make unrelated processing a condition for access to the service. Article 7 focuses on whether the processing you are asking consent for is directly tied to the service being provided.
What counts as “directly related” processing under Saudi Personal Data Protection Law (KSA PDPL) Article 7?
It means the service or benefit genuinely depends on that specific processing. If the service can still reasonably be provided without that processing, it is typically not “directly related” in practice.
If a company says “consent is required for security,” does that automatically satisfy Article 7?
Not automatically, the key test is whether the processing is directly required for the service or benefit. Article 7 is about necessity and direct connection, not just how the request is labeled.
Under KSA PDPL, can an employer make an employee consent to unrelated data use as a condition of receiving a workplace benefit?
Generally no, consent should not be tied to a benefit unless the processing is directly related to providing that benefit. Article 7 is meant to prevent pressure to agree to processing that is not connected to what the person is trying to obtain.
If we offer a discount in Saudi Arabia only if the customer consents to extra data processing, is that “forced consent”?
It can be, if the discount is treated as a benefit that is conditioned on consent for processing that is not directly related to providing that benefit. Article 7 draws a line between necessary processing and unrelated add-ons.
Who is responsible for ensuring “no forced consent” compliance in a Controller and Processor setup?
The Controller is typically responsible, because it decides the terms of the service and what consent is requested. Article 7 is about how consent is used in offering a service or benefit, which is normally controlled by the Controller.
Common misconception, “If we put it in the terms, consent is voluntary.” Is that true under Saudi Personal Data Protection Law (KSA PDPL) Article 7?
No, wording alone does not make consent voluntary if the service is blocked unless the person agrees. Article 7 focuses on whether consent is being used as a condition for a service or benefit when the processing is not directly related.
Does Saudi Personal Data Protection Law (KSA PDPL) Article 7 stop us from collecting extra data, as long as we make it optional?
No, the rule is not “never collect extra data,” it is “do not force consent for unrelated processing as the price of access.” If the additional processing is not directly tied to the service, Article 7 points toward keeping it separate and genuinely optional.
