Overview
Saudi Personal Data Protection Law (KSA PDPL) Article 22 establishes a mandatory requirement for conducting a Personal Data Protection Impact Assessment (DPIA) before a Controller initiates any Processing activity that relates to a product or service. The assessment aligns the Processing with the PDPL, evaluates risks to individuals, and ensures that Processing operations meet the safeguards and procedural controls defined by the Regulations.
Article 22 strengthens proactive compliance by making DPIAs part of the design stage for new or modified Processing activities.
Saudi PDPL Article 22
The Controller shall conduct an impact assessment of Personal Data Processing in relation to any product or service, based on the nature of the activity carried out by the Controller, in accordance with the relevant provisions of the Regulations.
Explanation of Saudi PDPL Article 22
DPIA Requirement Scope
This provision requires the Controller to conduct an impact assessment (DPIA) whenever Personal Data Processing relates to any product or service. The obligation applies because the requirement is tied to the nature of the activity itself.
The assessment ensures that Processing decisions are supported by a structured review that reflects the Controller’s operational context.
Assessment Based on Processing Nature
The Article specifies that the assessment must be based on the nature of the activity undertaken by the Controller. This means the DPIA must reflect the actual Processing environment, the characteristics of the operation, and the associated implications.
The wording requires Controllers to align their evaluations with the specific activity in question rather than relying on generic or unrelated assessments.
Alignment With Regulations
The Article states that the assessment must be conducted in accordance with the relevant provisions of the Regulations. This ties the DPIA to the procedural, documentary, and safeguard requirements that the Implementing Regulations will define.
Controllers must therefore follow the Regulation’s methods, timings, and prescribed content when carrying out the assessment to ensure compliance.
