Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements says that Controllers must keep detailed and accurate records of all personal data processing activities. These records help demonstrate compliance with the PDPL and must be maintained in a written format, kept up to date, and made available to SDAIA upon request. Even after the processing ends, the records should be preserved for five years. This requirement also aligns with the obligation to destroy data under certain conditions.
Maintain written, accurate records of all personal data processing for five years after processing ends, and share them with SDAIA when asked.
First: Personal Data Processing Activities Records Requirements
Pursuant to Article (31) of the Law, a Controller shall maintain records of personal data processing activities in accordance with the nature of its activities to be made available upon request by the competent authority without prejudice to the provisions of Article (18) of the Law regarding data destruction. Furthermore, as stipulated in Article (33) of the Regulations, when preparing records of personal data processing activities, a Controller shall:
Retain Processing Records:
1. Maintain the records of personal data processing activities for a period of five years following the cessation of each processing activity.
Written Format Required:
2. Ensure that the records of personal data processing activities are maintained in written form.
Ensure Accuracy & Currency:
3. Ensure the accuracy and up to date of the records of personal data processing activities.
Provide on Demand:
4. Make the records of personal data processing activities available to the competent authority upon request.
Explanation of First: Personal Data Processing Activities Records Requirements
Maintain logs for five years:
Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements say that Controllers must retain records of each processing activity for five years after that activity ends.
Maintain documentation in writing:
Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements also say that records must be documented in written form—digital or physical—but not just informally kept or remembered.
Keep records correct and up to date:
Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements also say that Controllers must ensure that their processing activity records are accurate and reflect the latest state of the activity.
Share records with authority upon request:
Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements also say that SDAIA can request access to these records at any time, and controllers must be able to produce them promptly.
