DPO Arabia

Third Parties, Contracts & Transfers

Govern third parties, disclosures and cross-border transfers with evidence.

We assess third-party processing, contractual requirements, disclosures and Personal Data transfers outside the Kingdom under the Saudi Personal Data Protection Law (PDPL) through one connected governance lifecycle.

Our role is to connect onboarding, role assessment, contracting, disclosure, foreign access and cross-border transfer safeguards so the relationship remains governed end to end.

07

CORE SERVICES

THIRD PARTY

RISK-LED

TRANSFERS

SAFEGUARD-READY

THE OPERATING MODEL

Govern each third-party relationship from processing purpose through contract and cross-border transfer.

We bring role allocation, processor obligations, disclosure, foreign access, transfer basis and safeguards into one governed lifecycle so contractual and transfer decisions reflect the actual processing relationship.

01

Role before contract

We determine whether the relationship is Controller-to-Processor, Controller-to-Controller or another processing arrangement before selecting the agreement.

02

Processor accountability

We screen processing scope, locations, sub-processors, security, retention and support access, then translate the relevant requirements into the Data Processing Agreement (DPA).

03

Transfer governance

We identify transfers and remote access outside the Kingdom, establish the applicable transfer route and conduct the required transfer risk assessment.

04

Safeguard execution

We implement the applicable Saudi Data & AI Authority (SDAIA) Standard Contractual Clauses (SCCs) template or BCR route where required, retain execution evidence and reassess material changes.

FROM OBLIGATION TO EVIDENCE

Move every third-party relationship through one connected governance cycle.

We operate the relationship through one governance path: understand the processing, assess the PDPL implications, establish the right contractual or transfer safeguards, and retain evidence as the relationship changes.

This lets us manage each relationship as an operating control rather than a one-time contract exercise, with role, location, access, safeguards and review triggers kept aligned as the service changes.

01
Discover
We identify the third party, role, processing purpose, Personal Data, locations, access, recipients and sub-processors.
02
Assess
We evaluate processor controls, disclosure requirements, foreign access and whether a cross-border transfer exists.
03
Contract
We put the appropriate DPA, Data Sharing Agreement (DSA) and transfer safeguards in place for the relationship.
04
Monitor
We track material changes in processing, sub-processors, locations, contracts, transfer risks and retained evidence.

CONTINUOUS THIRD-PARTY GOVERNANCE

The result is a relationship that can be reassessed when processing, sub-processors, locations, contracts or transfer conditions change.

WHEN THE DPO OFFICE ACTS

Bring these third-party and transfer triggers into the DPO Office early.

When these events occur, we reassess the role, processing, contract, disclosure position, transfer conditions and safeguards before the change becomes an unmanaged dependency.

Early review lets us resolve role, contracting and transfer dependencies before onboarding or change, rather than remediating them after Personal Data is already being processed.

Trigger

Change requiring attention

Response

New third party

Determine role, processing scope, Personal Data and contractual requirements before onboarding.

DPO REVIEW

Remote foreign access

Support, administration or other access from outside Saudi Arabia may create a cross-border transfer requiring assessment.

DPO REVIEW

New sub-processor

Review role, location, processing scope, contractual controls and transfer implications.

DPO REVIEW

Contract or service change

Reassess processing purpose, Personal Data, retention, disclosures, locations and transfer safeguards.

DPO REVIEW

GOVERNANCE SERVICE CATALOGUE

Seven services we can scope around processor, contract and transfer governance.

Start with the third-party, contractual or transfer requirement that needs to move. We can deliver it as a defined scope or connect adjacent PDPL DPO services where the same relationship creates governance, operational or assurance dependencies.

01

Processor / Third-Party Screening

Assess processing scope, locations, sub-processors, security and privacy practices, contractual readiness and PDPL-specific gaps.

02

Data Processing Agreement (DPA)

Document processor obligations, instructions, safeguards, sub-processing conditions, assistance duties and processing terms.

03

Data Sharing Agreement (DSA)

Govern controller-to-controller disclosures by documenting purpose, responsibilities, data scope and applicable safeguards.

04

Transfer Impact & Risk Assessment (TIA/TRA)

Assess transfer conditions, destination risks, foreign access considerations and the safeguards required for the transfer.

05

SDAIA Standard Contractual Clauses (SCCs)

Support selection, completion and execution of the applicable SDAIA-issued SCCs template for the transfer relationship.

06

Cross-Border Transfer & Disclosure Compliance

Coordinate transfer mechanisms, disclosure requirements, supporting agreements, assessments and evidence registers.

07

Binding Common Rules (BCRs) & Intra-group Transfers

Structure group-wide transfer governance, entity scope, binding mechanisms, operational controls and evidence for qualifying intra-group transfers.

SDAIA KSA PDPL CONTEXT

Regulatory references behind this service category.

These are the KSA PDPL requirements our Third Parties, Contracts & Transfers services are designed to operationalise through assessment, agreements, safeguards and retained evidence.

PDPL Implementing Regulation Article 17 – Choosing the Processor

Requires Controllers to select Processors that provide sufficient guarantees and to govern the processing relationship through appropriate contractual and oversight controls.

PDPL Implementing Regulation Article 20 – Disclosure of Personal Data

Sets operational controls for Personal Data disclosures, including documenting the disclosure and applying the relevant legal conditions and safeguards.

Regulation on Personal Data Transfer Outside the Kingdom

Provides the regulatory framework for transferring or disclosing Personal Data outside the Kingdom, including applicable safeguards, exemptions and risk-assessment requirements.

Standard Contractual Clauses (SCCs) For Personal Data Transfer – Introduction

Introduces the SDAIA Standard Contractual Clauses as a contractual safeguard for qualifying Personal Data transfers outside the Kingdom.

DPO GUIDES

Need the detailed method behind a third-party or transfer decision?

The guides provide deeper working detail where your team wants to understand the method. The service scope remains focused on assessing the relationship, putting the required agreements and safeguards in place, and maintaining the evidence for you.

01

PROCESSOR DUE DILIGENCE

How to Assess a Processor before Onboarding

The Guide provides deeper context on the questions to resolve before appointing a new Processor or third party that will process or access Personal Data, including processing scope, locations, controls and sub-processor chains.

02

PROCESSOR CONTRACTING

What a KSA PDPL DPA Needs to Cover

The Guide is useful when controller-to-Processor obligations need to be translated into a contract and the DPO Office needs to verify that the agreement reflects the actual processing arrangement.

03

TRANSFER ASSESSMENT

How to Conduct a TIA / TRA

The Guide is useful when personal Data may leave Saudi Arabia or be remotely accessed from abroad and the transfer conditions, risks and required safeguards need to be assessed and documented.

04

TRANSFER SAFEGUARDS

How to Use SDAIA Standard Contractual Clauses

The Guide is useful when sDAIA Standard Contractual Clauses are the selected transfer safeguard and the correct template, parties, annexes and execution evidence need to be put in place.

BUILD THE RIGHT SCOPE

Need one third-party control or ongoing DPO Office ownership?

Bring us the third-party relationship, contractual gap or cross-border transfer requirement. We can scope the relevant screening, contracting and transfer controls as a defined engagement or connect them into a broader DPO Office model where ongoing third-party oversight is required.

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