Disclosure & DSA Register
Keep a traceable record of Personal Data disclosures and the agreements that govern them.
DPO Arabia establishes and maintains a structured Disclosure & Data Sharing Agreement (DSA) Register that records each recurring or material disclosure, its recipient, purpose, Personal Data, disclosure condition, DSA status, geography, transfer safeguards, ownership and review evidence.
We operate the register as a disclosure-assurance layer so the Data Protection Officer (DPO) Office can trace why Personal Data is shared, how the recipient relationship is governed and what evidence supports each disclosure.
REGULATORY BASIS
KSA PDPL Articles 15 and 16, and Implementing Regulation Article 20
OPERATING FOCUS
Recipient, purpose, Personal Data, disclosure condition, frequency, DSA status, geography, transfer safeguards, ownership and review
OUTCOME
A current disclosure evidence register showing what Personal Data is shared, why the disclosure is permitted, how the relationship is governed and which disclosures require further action
TYPICAL TRIGGERS
Bring this DPO service into the workflow when these events occur.
Each trigger can create a new privacy decision, control requirement or evidence obligation that should be assessed and retained.
01
New recurring disclosure
02
New Controller-to-Controller sharing arrangement
03
DSA executed or amended
04
New recipient or disclosure purpose
05
Cross-border disclosure introduced
06
Existing disclosure materially changes
WHY IT MATTERS
Keep every material disclosure connected to the decision and agreement behind it.
We connect each material disclosure to the recipient, purpose, permitted condition, restrictions, governing agreement, Record of Processing Activities (RoPA), Privacy Notice and cross-border evidence where relevant. This gives the DPO Office a traceable disclosure record instead of an agreement list with no decision context.
A disclosure should remain traceable after it happens. The register preserves the decision, recipient, agreement and transfer evidence needed to demonstrate how that sharing was governed.
WHAT DPO ARABIA DELIVERS
Build a disclosure evidence register that connects each sharing arrangement to the governance behind it.
The service creates a practical portfolio view of recurring and material disclosures, so the DPO Office can see which sharing arrangements are validated, contractually governed, transfer-assessed and current.
01
Disclosure Register structure
Define the fields, statuses, ownership, review rules and evidence links required to govern disclosures consistently.
02
Recipient & disclosure mapping
Record the recipient, role, purpose, Personal Data, Data Subjects, frequency and disclosure channel.
03
Disclosure condition & restriction record
Document the applicable Personal Data Protection Law (PDPL) disclosure condition and any restrictions, approvals or dependencies relevant to the sharing.
04
DSA status & agreement linkage
Track whether a DSA exists, is required, under negotiation, executed, expired or subject to review.
05
Cross-border safeguard linkage
Identify disclosures outside Saudi Arabia and connect them to the relevant Transfer Impact Assessment (TIA)/Transfer Risk Assessment (TRA), Standard Contractual Clauses (SCCs) or other transfer evidence.
06
Register governance & reporting
Maintain ownership, review dates, material changes, open gaps and management-ready status across the disclosure portfolio.
HOW WE WORK
Define the register, reconcile the disclosures and keep the governance evidence current.
The four-stage workflow connects each material disclosure to its recipient, permitted condition, agreement status, transparency record and cross-border safeguards so the evidence remains usable for assurance and review.
01
Define the register
Agree the required disclosure fields, statuses, ownership, evidence links and review rules.
02
Populate & reconcile
Identify recurring and material disclosures and reconcile them against RoPA, contracts, DSAs, Privacy Notices and transfer records.
03
Validate the governance
Check the disclosure condition, recipient role, agreement status, cross-border implications and any outstanding gaps.
04
Maintain & report
Update the register as recipients, purposes, agreements or safeguards change and use it for assurance and regulatory readiness.
EVIDENCE YOU RETAIN
Keep each material disclosure traceable from its permitted condition through agreement and transfer evidence.
We retain evidence showing why the disclosure is permitted, who receives the Personal Data, how the sharing arrangement is governed and whether transparency or cross-border controls remain complete and current.
KSA PDPL REGULATORY CONTEXT
Connect the disclosure register to the permitted basis, restrictions and documentation duties behind each disclosure.
We use the KSA PDPL disclosure conditions, restrictions and documentation obligations to structure the register around the decisions and evidence the Controller needs to retain for each material sharing arrangement.
Saudi PDPL Article 15 – Permitted Personal Data Disclosure Conditions
Establishes the circumstances in which Personal Data may be disclosed and provides the core disclosure condition that the register should capture.
Saudi PDPL Article 16 – Prohibited Personal Data Disclosures Despite Exceptions
Sets circumstances where disclosure must not proceed even where an Article 15 condition may otherwise apply.
PDPL Implementing Regulation Article 20 – Disclosure of Personal Data
Requires purpose limitation, privacy protection, data minimisation and documentation of disclosure operations, including dates, methods and purposes.
RELATED DPO GUIDE
Need deeper context on governing recurring PDPL registers?
The related DPO Guide provides deeper context on how disclosure, agreement and other recurring PDPL records should be structured, owned and maintained as part of one connected DPO Office evidence system.
ASSURANCE & EVIDENCE
Which PDPL Registers Should a DPO Office Maintain?
USE WHEN: structuring disclosure, agreement and other PDPL registers into one governed evidence model.
RELATED ASSURANCE & EVIDENCE SERVICES
Connect the disclosure register to the agreement, cross-border governance and remediation evidence around it.
Use the adjacent services to govern Controller-to-Controller sharing, manage disclosures outside Saudi Arabia and drive missing agreements, unvalidated disclosure conditions or incomplete safeguards to evidence-backed closure.
01
DATA SHARING
Data Sharing Agreement (DSA)
We document the purpose, responsibilities and controls governing Controller-to-Controller disclosure or sharing.
02
CROSS-BORDER GOVERNANCE
Cross-Border Transfer & Disclosure Compliance
We coordinate the transfer basis, disclosure conditions, risk assessment and safeguards as one cross-border control record.
03
Remediation
PDPL Remediation Tracker
We assign findings, evidence corrective action and maintain accountable closure through the remediation cycle.
NEXT STEP
Need a Disclosure & DSA Register as a focused service or part of your DPO Office?
Share your current disclosures, DSAs, RoPA, transfer records and any known evidence gaps. We can shape the work as a focused Disclosure & DSA Register engagement or connect it to the wider Assurance & Evidence support you need.