KSA PDPL » Guidelines for Binding Common Rules (BCR) For Personal Data Transfer – Purpose

Guidelines for Binding Common Rules (BCR) For Personal Data Transfer – Purpose

This article is verified from SDAIA
halaprivacy.com
Athif Mohammed
Published: November 16, 2025
Updated: December 23, 2025

Overview

Guidelines for Binding Common Rules (BCR) for Personal Data Transfer – Purpose defines the purpose and regulatory role of Binding Common Rules as an approved safeguard for transferring personal data outside the Kingdom of Saudi Arabia (KSA). Issued under the Saudi Personal Data Protection Law (PDPL) and its Regulations, these Guidelines explain how BCRs ensure that personal data transferred to countries or international organizations without an adequate level of protection remains subject to safeguards equivalent to those required under Saudi law.

They also clarify how BCRs operate alongside other approved transfer mechanisms, including Standard Contractual Clauses and certification-based safeguards, within the PDPL cross-border transfer framework.

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.

Purpose

The purpose of these rules is to ensure that a level of protection for personal data is applied that is not less than the level of protection prescribed by the Law and its Regulations. This is achieved by specifying obligations of the parties involved in the transfer when personal data is transferred or disclosed to a country or international organization that does not have an adequate level of protection for personal data. This document provides comprehensive instructions for a range of entities operating within and outside the Kingdom regarding the preparation of Binding Common Rules. Binding Common Rules are considered one of the appropriate safeguards that data controllers may use, in addition to processors acting on behalf of and based on the instructions of the data controller. They are also used alongside standard contractual clauses and certifications from an entity licensed by the competent authority, in accordance with the provisions governing the transfer of personal data outside the Kingdom.

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.

Ensuring Equivalent Protection Levels

The primary purpose of these Guidelines is to ensure that personal data transferred outside the Kingdom continues to benefit from a level of protection that is not less than the level prescribed under the Personal Data Protection Law (PDPL) and its Regulations.

This principle of equivalence is central to the PDPL’s approach to international personal data transfers and applies regardless of the location of the recipient entity.

Regulating Transfers to Non-Adequate Jurisdictions

The Guidelines specifically address scenarios where personal data is transferred or disclosed to a country or international organization that does not provide an adequate level of personal data protection. In such cases, Binding Common Rules serve as a structured mechanism to compensate for the absence of adequacy by imposing enforceable obligations on the parties involved in the transfer.

Defining Obligations of Involved Parties

These Guidelines achieve their purpose by specifying clear obligations for Controllers, Processors, and other group entities involved in the transfer of personal data. By setting out these obligations, the Guidelines ensure that accountability, transparency, and enforceability are maintained throughout the lifecycle of the transferred data, even when processing occurs outside the Kingdom.

Supporting BCR Preparation and Implementation

The document provides comprehensive instructions to entities operating both within and outside the Kingdom on how to prepare Binding Common Rules in a manner that complies with Saudi regulatory expectations. This includes guidance on governance structures, internal controls, and operational safeguards necessary to make BCRs effective and binding across group entities.

Positioning BCRs Within the Transfer Framework

The Guidelines confirm that Binding Common Rules are one of the appropriate safeguards available to Controllers under the PDPL. This mechanism is designed for Controllers, who remain responsible for transfers even when Processors act on their behalf.

BCRs operate alongside other approved transfer mechanisms, such as Standard Contractual Clauses (SCCs) and certifications from licensed entities, forming part of a comprehensive cross-border transfer framework.

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