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Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Introduction
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – First: Preparation Phase
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Second: Assessing Negative Impacts and Potential Risks of Personal Data Processing
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Third: Risk Assessment for Data Transfer or Disclosure to Entities Outside the Kingdom
Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Fourth: Guidelines for Identifying Factors Related to the Analysis of Implications for the Vital Interests of the Kingdom

Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Third: Risk Assessment for Data Transfer or Disclosure to Entities Outside the Kingdom

  • This article is verified from SDAIA
  • halaprivacy.com
  • Updated: December 23, 2025
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Overview

Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Third: Risk Assessment for Data Transfer or Disclosure to Entities Outside the Kingdom establishes mandatory steps for evaluating risks associated with transferring or disclosing personal data beyond the borders of the Kingdom of Saudi Arabia. This phase confirms when risk assessments are required under the Transfer Regulation, analyzes the nature and scope of cross-border data transfers, evaluates the compliance posture of recipient entities, and assesses the adequacy of safeguards implemented to reduce negative impacts and potential risks.

The objective is to ensure that personal data transfers outside the Kingdom are carried out only after documented, proportionate, and effective risk mitigation measures are in place.

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.

Third: Risk Assessment for Data Transfer or Discloser to Entities Outside the Kingdom

This phase includes the steps required to assess the risks of transferring or disclosing personal data to entities outside the Kingdom. During this phase, entities should adhere to the following steps:

  1. Risk assessment procedures for the transfer or disclosure of personal data are mandatory: The obligation to assess the risks associated with the transfer or disclosure of personal data must be verified by determining the presence of any conditions outlined in Paragraph (1) of Article (VII) of the Regulations, as detailed below:

    1. Transfer of personal data outside the Kingdom or disclosure to entities outside the Kingdom, as specified in Article (IV) of the Regulations.

    2. Transfer sensitive data outside the Kingdom or disclose it to entities outside the Kingdom on a continuous or large scale.

  2. If the procedures and steps outlined in Clauses (I) and (II) above are not carried out, they must first be executed, then reviewed, and subsequently the previous steps in Clauses (I) and (II) should be specified (Since the subsequent steps rely on the previous steps outlined in Sections (I) and (II) above, the effectiveness of the guideline depends on ensuring the consistency and integration of these steps to achieve its intended purpose.), taking into account the following aspects (additional elements related to transfer or disclosure outside the Kingdom):

    1. Nature of Data Transfer or Disclosure: The nature of data transfer or disclosure involves analyzing phases of transferring or disclosing personal data to entities outside the Kingdom. This includes remote access, collecting personal data for transfer and processing abroad, collecting data of individuals in the Kingdom from external entities, storing or retaining data outside the Kingdom, transferring data for storage or processing outside the Kingdom, and disclosing data to external parties. It also considers the frequency of these operations, their scope regarding categories of data holders, as well as the content of the personal data.

    2. Entities Receiving Transferred Personal Data: Verifying the compliance of entities receiving disclosed personal data with the provisions of the Law and its Implementing Regulations, particularly those related to disclosure, transit, and subsequent transfer. This includes evaluating the adequacy of the standards and technical measures implemented by the entity to ensure data security, as well as the legal regulations governing the entity/entities to which the personal data will be transferred.

    3. Evaluating the adequacy of measures implemented to reduce negative impacts and potential risks, or identifying and applying additional measures to mitigate risk levels.

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.

Mandatory Nature of Risk Assessments

This phase establishes that conducting a risk assessment is not optional when transferring or disclosing personal data outside the Kingdom. Entities must first confirm whether any of the regulatory conditions triggering a mandatory assessment are present under the Transfer Regulation.

1. Conditions Triggering Risk Assessment

Risk assessments are required when personal data is transferred or disclosed outside the Kingdom, or when sensitive personal data is transferred on a continuous or large-scale basis. These conditions reflect scenarios with heightened risk to data subjects and increased regulatory exposure.

2. Dependency on Prior Assessment Phases

This phase depends on the proper completion of the Preparation Phase and the Assessment of Negative Impacts and Potential Risks Phase. If earlier steps have not been completed, entities must return to execute and document them before proceeding, ensuring consistency and traceability across the assessment lifecycle.

A. Nature of Data Transfer or Disclosure

Entities must analyze how personal data is transferred or disclosed outside the Kingdom. This includes assessing remote access, offshore processing, external data collection, cross-border storage or retention, onward disclosures, and the frequency, scope, and categories of personal data involved.

B. Assessment of Recipient Entities

Entities receiving personal data outside the Kingdom must be evaluated for compliance with the Law and its Implementing Regulations. This includes reviewing their legal environment, technical and organizational security measures, and controls related to disclosure, transit, and subsequent transfers.

C. Evaluation of Risk Mitigation Measures

Entities must assess whether existing safeguards sufficiently reduce identified risks and negative impacts. Where gaps are identified, additional legal, technical, or organizational measures must be applied to lower risk levels to an acceptable threshold prior to transfer.

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