Overview
Personal Data Disclosure Cases: Fifth: Disclosure is Limited to Subsequent Personal Data Processing that Does Not Result in the Identification of the Personal Data Subject or Any Other Individual in Particular addresses disclosure that is limited to subsequent Personal Data processing where such processing does not result in identifying the Personal Data Subject or any other individual. It emphasizes purpose limitation, due diligence, data minimization, and safeguards where data relates to individuals other than the Data Subject.
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.
Fifth: Disclosure is Limited to Subsequent Personal Data Processing that Does Not Result in the Identification of the Personal Data Subject or Any Other Individual in Particular
If the disclosure is limited to subsequent data processing that does not lead to identifying the data subject or any other individual in particular. The Controller shall ensure that a request for disclosure is directly related to a specific and clearly defined purpose or subject matter.
Due diligence shall be exercised to protect the privacy of the data subject or any other individual. Disclosure shall be limited to the minimum personal data necessary to achieve its purpose.
Moreover, the Controller disclosing personal data related to an individual other than the data subject shall be obligated to exercise due diligence and implement adequate safeguards to protect the privacy of that other individual.
Such measures shall include balancing the rights of the data subject with those of the other individual on a case-by-case basis and, where possible, anonymizing personal data that directly identifies the other individual.
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.
Subsequent Processing Without Identification
This case applies where disclosure is limited to subsequent Personal Data processing that does not lead to identifying the Data Subject or any other individual.
Purpose Limitation and Due Diligence
The Controller must ensure that the disclosure request is directly related to a specific and clearly defined purpose or subject matter. Due diligence must be exercised to protect the privacy of the Data Subject and any other individual.
Data Minimization
Disclosure must be limited to the minimum Personal Data necessary to achieve the stated purpose.
Protection of Other Individuals
Where disclosed Personal Data relates to an individual other than the Data Subject, the Controller must exercise due diligence and implement adequate safeguards to protect that individual’s privacy. These safeguards include balancing the rights of the Data Subject with those of the other individual on a case by case basis and, where possible, anonymizing Personal Data that directly identifies the other individual.
