White Paper

Comparative analysis of the GDPR and selected Middle East Privacy Laws

The fast-evolving technological developments and various personal data breach incidents are increasingly reminding businesses and organisations of the importance of safeguarding personal information. With the rise of cyber threats and privacy concerns, countries around the world are enacting new legislation aimed at regulating the collection, storage, and processing of personal data. Among these regulations, the General Data Protection Regulation stands out as a comprehensive framework governing data protection within the European Union (EU) and beyond. However, outside the EU, different jurisdictions have their own sets of data protection laws tailored to their legal, cultural, and economic landscapes.

In our efforts to raise awareness of the data protection frameworks, we created a comparative table that delves into a comparative analysis of the GDPR and data protection laws in the United Arab Emirates (UAE), the Kingdom of Saudi Arabia (KSA), Dubai International Financial Centre (DIFC), and Abu Dhabi Global Market (ADGM).

The comparative table compares various aspects of each piece of legislation (e.g. material and territorial scope, data processing bases, data subject rights, or obligations regarding the appointment of DPO, conducting Privacy Impact Assessments, and reporting data breaches).

To make reading the table easier, various colours have been used to indicate similarities between chosen data protection laws. The only exception is the red colour which highlights major differences that should particularly be taken into account. The table might be especially useful for larger organisations that operate within different GCC jurisdictions.

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