KSA PDPL » Rules for Appointing Personal Data Protection Officer (DPO) Article 4 – Applies to all PDPL Controllers

Rules for Appointing Personal Data Protection Officer (DPO) Article 4 – Applies to all PDPL Controllers

This article is verified from SDAIA
halaprivacy.com
Athif Mohammed
Published: November 13, 2025
Updated: December 23, 2025

Overview

Rules for Appointing Personal Data Protection Officer Article 4 sets out the minimum eligibility and suitability requirements that a Controller must consider when appointing a DPO under the Saudi Personal Data Protection Law (PDPL).

It establishes baseline standards relating to qualifications, experience, regulatory knowledge, integrity, and appointment models, ensuring that the DPO function is performed by competent and trustworthy individuals.

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.

Article 4: Requirements for DPO Appointment

When appointing DPO, Controller shall ensure that the following requirements are met:

Having appropriate academic qualifications and experience in the field of Personal Data protection.

Sufficient knowledge of risk management practices, including the management and handling of personal data breach incidents.

Having sufficient knowledge of regulatory requirements for Personal Data protection and other relevant regulatory requirements for performing DPO tasks.

Honesty and integrity, and not having been convicted of any offense involving dishonesty or breach of trust.

DPO may be an executive, employee of Controller or an external contractor.

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.

Article 4(1)(A)

Professional Qualifications Requirement

This provision requires the Controller to ensure that the appointed DPO has appropriate academic qualifications and practical experience in the field of personal data protection. The intent is to ensure that the DPO is capable of understanding and applying data protection principles, obligations, and controls under the Law and its Implementing Regulations.

Article 4(1)(B)

Risk Management Knowledge

This provision requires the DPO to possess sufficient knowledge of risk management practices, including the ability to manage and respond to personal data breach incidents. This provision requires the Controller to ensure that the appointed Personal Data Protection Officer (DPO) has sufficient knowledge of risk management practices, including handling personal data breach incidents.

Article 4(1)(C)

Regulatory Knowledge Requirement

This provision requires the DPO to have sufficient knowledge of personal data protection regulatory requirements, as well as any other relevant regulations necessary to perform DPO tasks effectively. This ensures that the DPO can guide the Controller on compliance obligations and regulatory expectations.

Article 4(1)(D)

Integrity and Trustworthiness

This provision establishes integrity as a core eligibility requirement for the DPO role. The appointed individual must demonstrate honesty and must not have been convicted of offenses involving dishonesty or breach of trust, reinforcing the sensitive and trusted nature of the DPO function.

Article 4(2)

Permissible Appointment Models

This provision clarifies that the DPO role may be fulfilled by different appointment models. The DPO may be an executive, an employee of the Controller, or an external contractor, provided that the eligibility requirements set out in this Article are met.

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