KSA PDPL » Saudi PDPL Article 19 – Mandatory Personal Data Protection Measures

Saudi PDPL Article 19 – Mandatory Personal Data Protection Measures

This article is verified from SDAIA
halaprivacy.com
Athif Mohammed
Published: November 10, 2025
Updated: January 10, 2026

Overview

Saudi Personal Data Protection Law (KSA PDPL) Article 19 requires Controllers to apply all necessary organizational, administrative, and technical measures to protect Personal Data during its entire lifecycle. These protections must match the sensitivity and risk level of the data and apply during all processing activities, including transfer.

Article 19 ensures that appropriate safeguards prevent unauthorized access, misuse, alteration, or disclosure in accordance with the Personal Data Protection Law (PDPL) and the Regulations.

SDAIA's Official PDPL 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 19

The Controller shall implement all the necessary organizational, administrative and technical measures to protect Personal Data, including during the Transfer of Personal Data, in accordance with the provisions and controls set out in the Regulations.

Plain-Language PDPL 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.

Required Protection Measures

This provision obligates Controllers to apply organizational, administrative, and technical safeguards to protect Personal Data. The protection must cover the entire lifecycle of the data, including any transfer.

The Article links these safeguards to the specific controls established in the Regulations, ensuring that protections are applied in a structured and consistent manner.

Each safeguard must correspond to the nature of the risks associated with the processing activity.

Organizational Controls for Compliance

This requirement reflects the need for internal structures that support Personal Data protection. Organizational controls involve establishing governance responsibilities, maintaining documented procedures, and following the regulatory framework referenced in the Regulations.

These measures ensure that data protection obligations are integrated into the overall management of processing activities.

Administrative Controls for Enforcement

Administrative measures are required to manage the way Personal Data is accessed and handled. These may include defined internal processes, oversight routines, role-based responsibilities, and other administrative actions referenced by the Regulations.

These measures help ensure that Personal Data is processed according to permitted purposes and that internal practices remain aligned with PDPL requirements.

Technical Controls for Data Security

The Article also requires Controllers to implement technical measures that address security risks. These measures must be capable of protecting Personal Data from unauthorized access or alteration during all stages of processing.

The Regulations establish the standards and controls that guide the implementation of these technical safeguards. Data protection must also be maintained during transfer.

Protection During Data Transfers

The obligation to protect Personal Data applies equally during transfer. The Article makes clear that safeguards must be applied when Personal Data moves between systems, entities, or environments.

Controllers must use the measures and controls outlined in the Regulations to ensure that data remains protected throughout the transfer process, regardless of the method or destination.

Frequently Asked Questions (FAQs)

Under the Saudi Personal Data Protection Law (KSA PDPL), who is responsible for implementing security measures, the Controller or the Processor?

The Controller is responsible for ensuring mandatory protection measures are applied, even when using a Processor. A Processor must follow the Controller’s instructions, but responsibility ultimately sits with the Controller.

Does Article 19 require specific technologies like encryption or multi factor authentication (MFA)?

Article 19 does not list specific technologies. It requires protective measures based on the nature of the data and the risks, with the Regulations adding more detail.

They can, but only as part of a broader set of measures that match the sensitivity and risks. Article 19 expects safeguards appropriate to the type of Personal Data being processed.

Does Saudi PDPL Article 19 require us to protect personal data even when it is stored with a cloud provider?

Yes, protection obligations apply regardless of where the data is hosted. Using a cloud vendor does not reduce the Controller’s responsibility.

For HR teams in KSA, do employee files need additional safeguards compared to general customer data?

Often yes, because HR data can be more sensitive, which increases the protection expected under Article 19. The safeguards should match the risk level.

In healthcare, does Article 19 cover both digital and paper records?

Yes, protection measures apply to any format of Personal Data. Physical files must receive protections that match their risk profile.

Can a business rely on a vendor’s certification alone to satisfy Article 19?

No, certification helps but does not replace the Controller’s obligation to ensure protective measures are actually implemented. Oversight remains necessary.

If a business has no history of breaches, can it relax its security controls under Saudi PDPL?

No, Article 19 requires measures based on risk, not past incidents. Absence of breaches does not remove the duty to protect data.

Does Article 19 cover internal threats such as employee misuse of data?

Yes, protection measures should address risks from both external and internal sources. Internal access controls are typically necessary.

In SaaS environments, do we need separate protections for test or staging environments?

Yes, Article 19 applies to all processing environments. If Personal Data is used in testing, it must receive appropriate safeguards.

Common misconception, “Cybersecurity alone satisfies Article 19.” Is that correct under Saudi PDPL?

No, Article 19 focuses on personal data protection broadly, which includes technical and organizational measures. Cybersecurity is part of compliance, not the whole requirement.

Does Article 19 require ongoing monitoring of security controls, or just initial setup?

The duty is continuous, because risks evolve over time. Controllers are expected to maintain and review measures suitable for the data they process.