Abstract
This paper examines Article 28 of the Kingdom of Saudi Arabia’s Personal Data Protection Law (PDPL), which governs the limitations on copying official documents containing identifiable information of data subjects. It explores the legal requirements, privacy implications, and compliance aspects related to document handling and copying, emphasizing the law’s allowance only under specific conditions such as legal obligations or public authority requests.
Keywords
KSA PDPL; Data Privacy; Document Copying; Legal Compliance; Data Subject Protection; Regulations; Public Authority Requests
Introduction
The Kingdom of Saudi Arabia’s Personal Data Protection Law (PDPL) Article 28 introduces critical restrictions on the copying of official documents containing identifiable information. This article seeks to enhance privacy for data subjects, ensuring that identifiable data in official documents remains protected and only accessible under legally sanctioned circumstances. This paper provides a detailed exploration of Article 28, examining its objectives, practical implications, and strategies for compliant document management.
Explanation
In essence, Article 28 prohibits the copying of official documents that contain identifiable data about individuals unless copying is either legally mandated or requested by a competent public authority under the regulations. This ensures that data subjects’ information is shielded from unnecessary distribution, strengthening data privacy.
Detailed Discussion
Key Strategic Points
- Compliance with Article 28 ensures that sensitive information in official documents is not freely copied, reducing risks of data leakage.
- It establishes a secure framework for handling identifiable data by limiting copying permissions.
- Encourages organizations to develop strategies and training focused on understanding when document copying is permissible.
General Activation Steps
- Implement clear internal policies outlining Article 28 requirements.
- Train staff on when and how copying of documents is allowed by law.
- Ensure audit trails are maintained for any copied documents to meet regulatory requirements.
Enablement Methodology
An enablement methodology involves educating teams on Article 28’s provisions, equipping them with tools to monitor and document any instances of copying, and establishing a reporting process to manage compliance with regulations.
Use Cases
- A government agency copying documents for lawful investigation purposes.
- Financial institutions retaining identifiable data copies in response to regulatory audits.
Dependencies
Compliance with Article 28 may depends on:
- Legal expertise to interpret when copying is legally permissible.
- Technological solutions to securely store and track copied documents.
Tools and Technologies
- Document Management Systems (DMS) with permission control settings.
- Encryption tools to protect copied data during storage and transfer.
Challenges and Risks
- Risk of non-compliance due to lack of awareness or improper training.
- Potential for unauthorized copying if document security controls are weak.
Conclusion
Article 28 of the KSA PDPL underscores the critical importance of limiting the duplication of documents containing identifiable data. By restricting document copying, this regulation provides a robust layer of protection for data subjects, ensuring their data remains secure. Organizations must align their practices with these legal requirements by implementing policies, deploying suitable tools, and training staff to understand the conditions under which copying is permitted. Compliance with Article 28 not only fulfills legal obligations but also strengthens data privacy and security within the organization.
References
- Saudi Data and Artificial Intelligence Authority. (2023).
- KSA PDPL – Kingdom of Saudi Arabia Personal Data Protection Law.
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