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Table of Contents

Personal Data Breach Incidents Procedural Guide – Introduction
Personal Data Breach Incidents Procedural Guide – Definitions
Personal Data Breach Incidents Procedural Guide – Scope
Personal Data Breach Incidents Procedural Guide – Stage One: SDAIA Notice
Personal Data Breach Incidents Procedural Guide – Stage Two: Breach Incident Containment
Personal Data Breach Incidents Procedural Guide – Stage Three: Documentation

Personal Data Breach Incidents Procedural Guide – Stage Two: Breach Incident Containment

Overview

Personal Data Breach Incidents Procedural Guide Stage Two sets out the mandatory containment and response actions that Controllers must implement after identifying a personal data breach under the Saudi Personal Data Protection Law (PDPL). This stage focuses on limiting harm, identifying affected data and individuals, and notifying Data Subjects when their rights or interests may be impacted. It aligns breach response practices with international standards while ensuring compliance with SDAIA notification expectations and PDPL requirements on transparency, risk mitigation, and individual protection.

In practice, Stage Two bridges regulatory notification and operational response by defining how Controllers must assess breach scope, contain damage, and communicate clearly with affected Data Subjects when required.

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 TWO: Breach Incident Containment

The Controller shall implement response and containment procedures for personal data breach incident in accordance with best international practices and relevant regulatory requirements, including, but not limited to, the following measures to control personal data breach incidents:

  1. Identifying type and quantity of personal data.

  2. Identifying type of breached personal data that can be changed (such as email addresses, passwords, confidential inquiries, credit card numbers, etc.) and taking actions to change this breached data.

  3. Identifying individuals affected by data breach incident based on type of personal data breached.

  4. The Controller shall notify the Data Subjects without undue delay if this results in damage to their data or conflicts with their rights or interests, including, but not limited to: Damages related to exercising the right of the data subject, physical harm such as stalking and assault, or economic damage, such as fraud or identity theft.

A. Notice Methods:

  1. The Controller may notify the Data Subject by any appropriate means in accordance with the preferred methods for communication by the Data Subject, including, but not limited to text messages, or e-mail.

  2. If the breach damage extends to a large group of people at the national level, the Controller may, provided, that the content of the notice complies with the applicable law requirements in the Kingdom, in addition to the provisions mentioned in paragraph (1) above, notify the Data Subject by other means, including, but not limited to, Controller's website, official controller's accounts on social media platforms, or media.

B. Notice Description:

The notice provided to the Data Subject shall be in a clear and simple manner and shall include the following:

  1. A detailed explanation of personal data breach incident.

  2. An explanation of the potential risks arising from that incident and the measures taken to prevent, avoid, or mitigate such consequences.

  3. The Controller's Name, contact details and its DPO (if any) or any other appropriate means of communication with the Controller.

  4. Guidelines and necessary advice that may assist the affected Data Subject in taking appropriate actions to avoid potential risks or mitigate their consequences, such as economic damages ex. fraud or identity theft.

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.

Breach Response and Containment Obligation

This stage requires Controllers to activate structured breach response and containment procedures immediately after a personal data breach is identified. The obligation is not limited to notification, but extends to operational actions that reduce risk, prevent further exposure, and protect Data Subjects from harm. The reference to international best practices reinforces that breach handling must be systematic, documented, and risk-based.

1. Identifying Breached Personal Data

Controllers must determine both the type and quantity of personal data involved in the breach. This assessment is essential to understand the seriousness of the incident, the sensitivity of the data exposed, and the potential impact on Data Subjects. Accurate identification supports proportional containment actions and appropriate notification decisions.

2. Addressing Changeable Compromised Data

Where breached personal data can be changed, such as passwords, login credentials, email addresses, or financial identifiers, the Controller must take prompt corrective action. This requirement emphasizes proactive mitigation to prevent further misuse of compromised data and reduce downstream risks such as fraud or unauthorized access.

3. Identifying Affected Data Subjects

Controllers must identify the individuals affected by the breach based on the type of personal data compromised. This step ensures that response actions and notifications are targeted, accurate, and relevant, rather than overly broad or insufficiently scoped.

4. Obligation to Notify Data Subjects

If a personal data breach results in damage to Data Subjects or conflicts with their rights or interests, the Controller must notify them without undue delay. The Guide explicitly recognizes different forms of harm, including interference with data subject rights, physical risks such as stalking or assault, and economic harm such as fraud or identity theft. This reflects PDPL’s harm-based notification threshold.

A. Notice Methods

Controllers may notify Data Subjects using appropriate communication methods aligned with the Data Subject’s preferred channels, such as email or text messages. Where a breach affects a large number of individuals at the national level, broader notification channels may be used, including the Controller’s website, official social media accounts, or other media, provided legal requirements in the Kingdom are met.

B. Notice Description

The notification to Data Subjects must be clear and simple. It must explain what happened, describe potential risks and mitigation measures, identify the Controller and contact points including the DPO where applicable, and provide practical guidance to help affected individuals protect themselves from further harm. This ensures transparency while empowering Data Subjects to take informed protective actions.

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