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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) – Introduction

Overview

Personal Data Processing Activities Records Guideline – Introduction explains the purpose and regulatory context of maintaining Records of Personal Data Processing Activities under the Saudi Personal Data Protection Law (PDPL). It clarifies SDAIA’s role in issuing this Guideline to support Controllers in meeting their statutory documentation obligations, highlights the linkage to Article (31) of the PDPL and Article (33) of the Implementing Regulations, and confirms that the Guideline provides practical assistance, including a sample RoPA template.

This section also emphasizes that the Guideline is interpretive in nature and does not replace the Law or 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.

Introduction

In fulfillment of its mandate to raise awareness among entities subject to the provisions of the Personal Data Protection Law, the “Law” and its Implementing Regulations, and to enable those entities to understand their obligations under Article (31) of the Law and Article (33) of the Implementing Regulations, the Saudi Data & AI Authority (SDAIA) has issued this Guideline to assist entities in preparing records of personal data processing activities.

This Guideline also provides a sample template for the records of personal data processing activities, designed to assist Controllers in complying with the Law’s provisions and Implementing Regulations when preparing their records of personal data processing activities. The terms and phrases used in this Guideline shall be construed in accordance with the definitions provided in the Law and its Implementing Regulations. This Guideline shall not be considered a binding legal document, nor shall it substitute consulting the Law and its Implementing Regulations, which shall constitute the regulatory reference for all matters related to the application of the Law’s provisions.

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.

Regulatory Purpose of the Guideline

This provision explains that the Guideline is issued as part of SDAIA’s mandate to raise awareness and support compliance with the Personal Data Protection Law and its Implementing Regulations. Its primary role is educational and facilitative, helping entities understand and operationalize their obligations related to maintaining records of personal data processing activities.

Legal Basis for RoPA Obligations

This section clarifies that the obligation to maintain records of personal data processing activities arises directly from Article (31) of the PDPL and Article (33) of the Implementing Regulations. The Guideline does not create new obligations, but rather explains how Controllers can practically comply with these existing legal requirements when documenting their processing activities.

Practical Support and Template Use

This paragraph explains that the Guideline includes a sample template designed to assist Controllers in preparing compliant records of personal data processing activities. The template serves as a reference tool to help ensure that records are structured in a manner consistent with the Law and Implementing Regulations, while allowing Controllers to adapt it to their operational realities.

Interpretation and Non-Binding Nature

This section confirms that all terms and phrases used in the Guideline follow the definitions set out in the PDPL and its Implementing Regulations. It also makes clear that the Guideline is not legally binding and does not replace the Law or Regulations, which remain the authoritative legal reference for compliance and enforcement purposes.

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