KSA PDPL » PDPL Implementing Regulation Article 21 – Controls for Processing Personal Data for Public Interest Purposes

PDPL Implementing Regulation Article 21 – Controls for Processing Personal Data for Public Interest Purposes

This article is verified from SDAIA
halaprivacy.com
Athif Mohammed
Published: November 11, 2025
Updated: December 23, 2025

Overview

PDPL Implementing Regulation Article 21 sets out the obligations that apply when a Public Entity collects Personal Data from sources other than the Data Subject, processes it for a new purpose, or requests Disclosure to achieve a public interest. The Article ensures public interest processing remains lawful, necessary, proportionate, and aligned with the legal mandate of the Public Entity.

It requires strict controls, minimal data use, documentation of operations, and implementation of administrative and technical safeguards consistent with the Law and Article 41 obligations.

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.

Article 21: Controls for Processing Personal Data for Public Interest Purposes

When a Public Entity collects Personal Data not directly from the Data Subject, processes it for a purpose other than the one for which it was initially collected, or requests Disclosure of such data to achieve a public interest, the Public Entity shall comply with the following:

Ensure that it is necessary to achieve a clearly defined public interest.

That the public interest is related to the mandate as specified by law.

Take suitable measures to limit the damage that may result, including implementing necessary administrative and technical controls to ensure its personnel’s compliance with the provisions of Article 41 of the Law.

Record those operations in the records of Personal Data Processing activities.

Collecting and Processing the minimum necessary Personal Data to achieve the purpose.

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. Public Interest Necessity

This provision requires the Public Entity to ensure that the Processing or Disclosure is genuinely necessary to achieve a clearly defined public interest.

2. Mandate Alignment Check

This provision requires the Public Entity to confirm that the public interest relates directly to its legal mandate as defined by applicable law.

3. Damage Limitation Measures

This provision requires the Public Entity to take appropriate steps to reduce potential harm. It includes implementing administrative and technical controls to ensure personnel comply with Article 41 requirements.

4. Record Processing Operations

This provision requires the Public Entity to document all such Processing or Disclosure in the records of Personal Data Processing activities.

5. Minimum Necessary Data

This provision requires the Public Entity to limit both the Collection and Processing of Personal Data to the minimum amount required to achieve the intended public interest purpose.

Saudi Personal Data Protection Law Compliance Services (KSA PDPL)

KSA PDPL Compliance Implementation

Achieve PDPL Compliance in 4 weeks or less.

Data Protection Officer As A Service (DPOaaS)

Let us handle your daily PDPL Compliance Operations.

KSA PDPL Compliance Audit (External)

Audit your PDPL compliance obligations.

Table of Contents

← PDPL Compliance Ecosystem