KSA PDPL » Saudi PDPL Article 37 – Inspection and Enforcement Powers

Saudi PDPL Article 37 – Inspection and Enforcement Powers

This article is verified from SDAIA
halaprivacy.com
Athif Mohammed
Published: November 10, 2025
Updated: January 11, 2026

Overview

Saudi Personal Data Protection Law (KSA PDPL) Article 37 defines SDAIA’s inspection and enforcement powers under the Personal Data Protection Law (PDPL). The Article authorizes the Competent Authority (SDAIA) to appoint inspectors, conduct compliance monitoring, investigate violations, and collaborate with criminal investigation bodies whenever necessary. It also empowers the Authority to seize tools, systems, or devices used in committing a PDPL violation until a final decision is issued.

This Article establishes the operational framework for oversight, investigation, and enforcement, ensuring lawful handling of personal data, consistent application of the Regulations, and coordinated responses to PDPL breaches across the Kingdom.

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 37

Employees and workers appointed by a decision of the president of the Competent Authority shall have the powers to control and inspect the violations stated in this Law or the Regulations. The president of the Competent Authority shall issue the rules and procedures in regard to the work of those employees and workers in accordance with the applicable laws.

The employees and workers referred to in Paragraph (1) of this Article may seek assistance from criminal investigations authorities or other competent authorities to carry out their duties concerning control and inspection of violations stipulated in the Law or Regulations.

The Competent Authority has the right to seize the means or tools used in committing the violation until a decision is made on it.

Plain-Language PDPL 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.

PDPL Article 37(1)

Inspection Authority Granted

This provision grants SDAIA the ability to appoint employees and workers who are legally empowered to inspect entities for PDPL compliance. These inspectors act under rules and procedures issued by the president of the Competent Authority, ensuring their activities are governed by clear legal standards.

This establishes a formal inspection mechanism to detect and address PDPL violations across all sectors.

PDPL Article 37(2)

Support From Authorities

This provision allows appointed inspectors to seek assistance from criminal investigation bodies or other competent authorities when performing inspection or control duties. This provision enables coordinated enforcement, expands investigative capability, and ensures that inspectors are supported in situations requiring law-enforcement expertise or multi-agency cooperation.

PDPL Article 37(3)

Seizure Powers Authorized

This provision empowers the Competent Authority to seize any tools, systems, or devices used in committing a PDPL violation. These items may be held until a final decision is issued in the case.

This ensures preservation of evidence, prevents further unlawful processing, and supports effective enforcement actions.

Frequently Asked Questions (FAQs)

What does SDAIA’s inspection power under the Saudi Personal Data Protection Law (KSA PDPL) actually mean in practice?

It means SDAIA can review how a Controller or Processor handles Personal Data to check compliance. This may include looking at documents, processes, or evidence showing how PDPL obligations are being met.

Can SDAIA request information during an inspection even if no complaint has been made?

Yes, SDAIA can act on its own initiative. Inspections do not require a complaint from a Data Subject.

Does an inspection under Article 37 mean the organization is already in trouble?

Not necessarily, as inspections can be routine or preventative. They only lead to consequences if violations are found.

Can a Controller refuse SDAIA’s inspection request if they think it is unnecessary?

No, Controllers are expected to cooperate. Article 37 supports SDAIA’s authority to access information relevant to compliance.

Who is responsible for preparing documents during an SDAIA inspection?

The Controller is primarily responsible for ensuring PDPL documentation is ready. Processors may also need to provide information relating to activities performed on behalf of the Controller.

Does SDAIA need to give advance notice before inspecting an organization?

Article 37 does not specify required notice conditions. In practice, inspections may be announced or unannounced depending on circumstances.

Can SaaS or cloud vendors be inspected if data is stored with them?

Yes, if they act as Processors involved in PDPL regulated processing. Article 37 allows SDAIA to review any party participating in the processing chain.

What happens if an organization provides incomplete or unclear information during inspection?

That can still be treated as non compliance. Article 37 expects honest, complete cooperation.

Is a Processor inspected separately from the Controller?

SDAIA may inspect both, especially if responsibilities are shared. The focus is on understanding whether PDPL obligations are being met across the processing lifecycle.

Yes, if relevant to the inspection. Article 37 allows SDAIA to verify compliance with operational practices connected to Personal Data use.

Is it a violation if the organization is simply unprepared for an inspection?

Being unprepared may expose gaps that qualify as violations. Article 37 puts the responsibility on organizations to maintain a compliance ready posture.

Common misconception, “SDAIA only inspects after a breach.” Is that accurate?

No, inspections can occur for various reasons, not only after breaches. SDAIA’s role includes proactive oversight to prevent issues before they escalate.