Personal Data Destruction, Anonymization, and Pseudonymisation Guideline — Phase Four: General Guidelines outlines general principles and operational best practices all controllers must follow when destroying, anonymizing, or pseudonymising personal data. It emphasizes legal compliance, internal security controls, staff training, secure handling of both digital and physical records, and the importance of maintaining logs and keeping up with new risks and technologies.
Securely manage, document, and continuously update data-handling practices.
Phase Four: General Guidelines
Lawful and Aligned:
1- All activities involving data anonymization, destruction, and Pseudonymisation shall be conducted in compliance with the Personal Data Protection Law, its Implementing Regulations, and any applicable regulatory requirements issued by relevant competent authorities.
Train Staff Regularly:
2- All employees involved in data security shall be adequately trained on the importance of secure data Pseudonymisation and anonymization.
Prevent Data Leakage:
3- The Controller shall ensure that no personal data is lost, misplaced, or disclosed to any unauthorized third party during the destruction, anonymization, or Pseudonymisation process.
Secure Physical Disposal:
4- All printed documents shall be disposed of in a manner that renders the personal data irretrievable (e.g., shredding using secure shredding machines and disposing of the waste securely) in accordance with the regulatory requirements issued by relevant competent authorities.
Keep Activity Logs:
5- Detailed records shall be maintained of all data anonymization and destruction activities, including the techniques used, the justification for their selection, and ensuring that such records are available upon request from the competent authority.
Review Techniques Periodically:
6- The Controller shall regularly review and update its data anonymization, destruction, and Pseudonymisation techniques to address emerging risks and technological advancements.
Explanation of Phase Four: General Guidelines
Follow PDPL and other rules:
Phase Four: General Guidelines says to ensure all destruction, anonymization, and pseudonymisation activities comply with PDPL, its Implementing Regulations, and any other regulator’s requirements.
Build employee awareness:
Phase Four: General Guidelines also says that employees involved in data security must be trained on secure methods of anonymization and pseudonymisation.
Secure handling during processing:
Phase Four: General Guidelines also says that No personal data should be lost, mishandled, or disclosed to unauthorized parties during destruction or anonymization processes.
Shred and discard safely:
Phase Four: General Guidelines also says that printed documents containing personal data must be shredded and discarded using secure methods approved by regulators.
Document actions and techniques:
Phase Four: General Guidelines also says to maintain detailed records of data destruction or anonymization, including chosen techniques and justifications, ready to share with SDAIA if requested.
Stay updated with risks:
Phase Four: General Guidelines also says to continuously evaluate and upgrade destruction, anonymization, and pseudonymisation tools and practices in line with tech and threat landscape evolution.
