KSA PDPL » Personal Data Breach Incidents Procedural Guide – Stage Three: Documentation

Personal Data Breach Incidents Procedural Guide – Stage Three: Documentation

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

Overview

Personal Data Breach Incidents Procedural Guide Stage Three establishes the documentation and record-keeping obligations that Controllers must follow after a personal data breach under the Saudi Personal Data Protection Law (PDPL). This stage ensures accountability by requiring Controllers to retain evidence of breach notifications, corrective actions, and response measures taken in coordination with SDAIA.

By mandating structured documentation and post-incident remediation, Stage Three supports regulatory oversight, continuous improvement, and demonstrates compliance with PDPL breach handling obligations and implementing regulations.

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.

STAGE THREE: Documentation

The Controller shall retain copies of the documents submitted to SDAIA regarding incidents of personal data breach, the corrective actions taken, and any relevant proper records or documents. The Controller shall take all corrective actions to contain personal data breach incidents, in accordance with lessons learned from it.

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.

Retention of Breach Documentation

Controllers are required to retain copies of all documents submitted to SDAIA in relation to personal data breach incidents. This includes notifications, reports, supporting materials, and any correspondence exchanged with the Competent Authority. The purpose of this requirement is to maintain a clear audit trail that evidences compliance with statutory breach notification and response obligations.

Recording Corrective Actions Taken

In addition to notification records, Controllers must retain documentation relating to corrective actions implemented following the breach. This includes technical, organizational, or procedural measures taken to address the incident, limit its impact, and prevent further compromise of personal data.

Maintaining Relevant Records and Evidence

Controllers must preserve any other relevant records or documents connected to the breach incident. This may include internal investigation reports, decision logs, risk assessments, and internal communications that support how the breach was assessed and managed. These records demonstrate due diligence and structured incident handling.

Implementing Lessons Learned

Stage Three goes beyond record retention by requiring Controllers to apply lessons learned from the breach incident. Controllers must take corrective actions informed by the incident analysis to improve controls, strengthen safeguards, and reduce the likelihood of similar breaches occurring in the future. This reinforces a continuous improvement approach to personal data protection governance.

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