Overview
Minimum Personal Data Determination Guideline – Third: Controller Obligations explains the core obligations imposed on Controllers to ensure continuous compliance with the Personal Data Minimization Principle under the Saudi Personal Data Protection Law (PDPL). It focuses on governance, accountability, documentation, and training requirements that must be embedded into processing operations.
The section emphasizes regular audits, purpose-based processing discipline, and privacy-by-design practices to prevent unnecessary or convenience-based data collection.
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.
Third: Controller Obligations
- Controllers shall regularly audit and review their Personal Data processing activities to ensure compliance with the Data Minimization Principle. They shall implement appropriate corrective measures through their employees or the Personal Data Protection Officer.
- When processing Personal Data for a purpose other than that for which it was collected, according to the conditions outlined in Article (10) of the Law, the Controller must ensure that all procedures specifying the data content are documented, including the operations related to the application of the Data Minimization Principle. The Controller must exercise caution to ensure that the purposes for collecting Personal Data are legitimate and specified. Accordingly, Controllers must not collect Personal Data simply because it is convenient to retain it, as this does not constitute a "necessary" purpose.
- Controllers must ensure that their employees responsible for collecting Personal Data receive adequate training to understand regulatory obligations regarding Data Minimization. This includes, in particular, training those responsible for designing systems and tools directly involved in the collection and processing of Personal Data to ensure the implementation of the Data Minimization Principle through a "privacy by design" approach.
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. Ongoing Reviews With DPO Oversight
This paragraph establishes that data minimization is not a one-time assessment but a continuous obligation. Controllers must regularly audit and review their Personal Data processing activities to confirm that only necessary data is collected and retained.
Where deficiencies are identified, Controllers must implement corrective measures through operational teams or under the supervision of the Personal Data Protection Officer to restore compliance.
2. Purpose Change and Documentation Discipline
This paragraph clarifies that when Personal Data is processed for a new purpose, as permitted under Article (10) of the Law, Controllers must reassess and document the necessity of the data content. Convenience or future usefulness does not qualify as a lawful necessity.
Controllers must ensure that every data element collected remains directly tied to a legitimate and clearly specified purpose, and that all related procedures are properly documented.
3. Training and Privacy by Design
This paragraph places responsibility on Controllers to ensure that employees involved in data collection and system design are adequately trained on data minimization obligations. Special emphasis is placed on personnel responsible for developing systems and tools used for Personal Data processing.
Controllers must embed the Data Minimization Principle into system architecture and operational workflows through a privacy-by-design approach to prevent excessive or unjustified data collection from the outset.
