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Table of Contents

Personal Data Processing Activities Records Guideline (RoPA) – Introduction
Personal Data Processing Activities Records Guideline (RoPA) – Objectives
Personal Data Processing Activities Records Guideline (RoPA) – First: Personal Data Processing Activities Records Requirements
Personal Data Processing Activities Records Guideline (RoPA) – Second: Contents of Personal Data Processing Activities Records
Personal Data Processing Activities Records Guideline (RoPA) – Third: Content Details of Personal Data Processing Activities Records

Personal Data Processing Activities Records Guideline (RoPA) – First: Personal Data Processing Activities Records Requirements

Overview

Personal Data Processing Activities Record Guideline – First: Personal Data Processing Activities Records Requirements define the mandatory obligations imposed on Controllers under the Saudi Personal Data Protection Law (PDPL) for maintaining records of personal data processing activities.

This section sets out the obligation to maintain records, how long they must be retained, the form in which they must be kept, and the obligation to make them available to the Competent Authority (SDAIA) upon request, in accordance with PDPL and its 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.

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:

  1. Maintain the records of personal data processing activities for a period of five years following the cessation of each processing activity.

  2. Ensure that the records of personal data processing activities are maintained in written form.

  3. Ensure the accuracy and up to date of the records of personal data processing activities.

  4. Make the records of personal data processing activities available to the competent authority upon request.

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.

Legal Obligation to Maintain Records

This provision explains that, pursuant to Article (31) of the Law, Controllers are legally required to maintain records of personal data processing activities in a manner proportionate to the nature of their operations. These records form part of the Controller’s accountability obligations and must be available to the Competent Authority upon request.

1. Retention Period for RoPA Records

This requirement clarifies that records of personal data processing activities must be retained for a period of five years following the cessation of each processing activity. This obligation applies without prejudice to data destruction requirements under Article (18) of the Law.

2. Written Form Requirement

This requirement emphasizes that records of personal data processing activities must be maintained in written form. This ensures traceability, auditability, and the ability to demonstrate compliance with PDPL obligations.

3. Accuracy and Ongoing Updates

This requirement explains that Controllers must ensure records remain accurate and up to date. Any changes to processing activities, purposes, systems, or recipients must be reflected promptly in the records.

4. Availability to the Competent Authority (SDAIA)

This requirement confirms that Controllers must make records of personal data processing activities available to the Competent Authority upon request. This enables regulatory oversight, compliance verification, and enforcement where necessary.

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