Overview
Saudi Personal Data Protection Law (KSA PDPL) Article 39 clarifies that government entities are responsible for disciplining their own employees when they violate the Personal Data Protection Law (PDPL) or its Implementing Regulations. These disciplinary actions operate within existing public-sector legal frameworks and established employee conduct procedures.
By assigning internal accountability to public bodies, Article 39 strengthens Saudi Arabia’s privacy governance model. It ensures that PDPL violations by civil servants are treated as administrative misconduct, complementing rather than replacing the other penalties under Articles 35 and 36.
Saudi PDPL Article 39
Explanation of Saudi PDPL Article 39
Internal Discipline Required
This provision states that when a public-sector employee violates the PDPL or its Regulations, the employing government entity must take disciplinary action consistent with the legal and regulatory procedures governing public employment. These disciplinary actions operate alongside penalties under Articles 35 and 36 but do not replace them.
This framework ensures public institutions remain accountable for the conduct of their workforce while maintaining established administrative disciplinary processes.
