DPO Arabia

Data Processing Agreement (DPA)

Put processor instructions, safeguards and accountability into the contract.

DPO Arabia reviews, drafts and negotiates Data Processing Agreements that translate the Controller’s Saudi Personal Data Protection Law (PDPL) obligations, Processor assessment findings and approved processing instructions into an executable contractual framework.

We align the Data Processing Agreement (DPA) to the Processor relationship that has actually been assessed, including the processing scope, locations, sub-processors, instructions, safeguards and conditions the Controller needs to enforce.

REGULATORY BASIS

KSA PDPL Article 8 and Implementing Regulation Article 17

OPERATING FOCUS

Processing purpose, Personal Data, duration, Controller instructions, breach notification, foreign-law exposure, sub-processors and accountability

OUTCOME

An executed DPA that reflects the actual Processor relationship and supports instruction, monitoring and compliance evidence

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 Processor onboarding

02

Existing Processor without a compliant DPA

03

Contract renewal

04

Material processing change

05

New sub-processor

06

Hosting or foreign-access change

WHY IT MATTERS

Make the contract reflect the Processor relationship you have actually approved.

We translate the due-diligence findings into relationship-specific contractual controls covering the service, Personal Data, purpose, duration, locations, sub-processors, instructions, security, cooperation and change conditions. This keeps the executed DPA aligned with the processing the Controller has assessed rather than relying on a generic agreement.

The contract should not describe a generic Processor relationship. It should document the specific processing the Controller has assessed and approved.

WHAT DPO ARABIA DELIVERS

Turn the assessed Processor relationship into enforceable contractual controls.

The service connects the processing facts established during due diligence with the contractual terms, instructions and governance controls needed for the Processor relationship.

01

DPA scope & processing schedule

Define the services, processing purpose, Personal Data categories, Data Subjects, processing duration, locations and relevant processing activities.

02

Controller instructions & Processor obligations

Document authorised instructions and the Processor’s obligations for compliant processing, confidentiality, security and cooperation.

03

Personal Data Breach obligations

Establish prompt Processor notification, incident information requirements, cooperation and escalation expectations.

04

Sub-processor governance

Identify existing sub-processors and define notification, approval, objection and downstream protection requirements.

05

Foreign-law & transfer provisions

Address other-country legal exposure and connect the DPA to applicable cross-border safeguards where foreign processing or access exists.

06

Execution, change & review controls

Track negotiation points, approvals, executed versions, renewal dates and material changes requiring reassessment.

HOW WE WORK

Move from an assessed Processor relationship to an executed, governed DPA.

The four-stage workflow keeps the processing facts, contractual requirements, negotiation record and final agreement connected in one evidence trail.

01

Confirm the processing

Validate the Processor role, services, Personal Data, purpose, duration, locations, access and sub-processors against the screening evidence.

02

Assess the contract

Review the proposed agreement and DPA against the Processor requirements and the actual processing arrangement.

03

Draft & negotiate

Prepare or amend the DPA, processing schedule and required contractual protections, resolving gaps with the Processor.

04

Execute & govern

Retain the executed agreement, record outstanding conditions and define renewal or material-change triggers.

EVIDENCE YOU RETAIN

Keep the executed agreement and the decisions behind it together.

The evidence set shows how the Processor relationship was translated into contractual requirements, what was negotiated and which version governs the approved processing.

KSA PDPL REGULATORY CONTEXT

Connect the DPA to the Controller’s Processor accountability obligations.

We use the KSA PDPL Processor-accountability requirements and the Implementing Regulation’s agreement, instruction, monitoring and sub-Processor conditions to structure the contractual controls for the assessed Processor relationship.

Saudi PDPL Article 8 – Controller Obligations for Processors

Requires Controllers to select Processors that provide sufficient guarantees, monitor their compliance and remain accountable for obligations toward Data Subjects and the Competent Authority.

PDPL Implementing Regulation Article 17 – Choosing the Processor

Sets the detailed agreement requirements, including processing purpose, Personal Data categories, duration, breach notification, foreign-law exposure, Controller instructions and sub-Processor engagement.

RELATED DPO GUIDE

Need a practical checklist for the Processor agreement?

The related DPO Guide provides deeper working context when drafting or reviewing a DPA to connect the agreement clauses with the processing facts and KSA PDPL Processor requirements that need to be addressed.

THIRD PARTIES, CONTRACTS & TRANSFERS

What a KSA PDPL DPA Needs to Cover

USE WHEN: drafting, reviewing or negotiating a Processor agreement and its processing schedule.

RELATED THIRD PARTIES, CONTRACTS & TRANSFERS SERVICES

Connect the DPA into the wider third-party governance lifecycle.

Where the requirement extends beyond this service, we connect the work to the related services that establish the Processor relationship, assess foreign processing or access and implement the applicable transfer safeguard.

01

THIRD-PARTY DUE DILIGENCE

Processor / Third-Party Screening

We assess third-party processing, security, location and compliance evidence before onboarding or material change.

02

TRANSFER RISK

Transfer Impact & Risk Assessment (TIA/TRA)

We assess the destination, access model, safeguards and residual risks of the proposed cross-border transfer.

03

TRANSFER SAFEGUARD

SDAIA Standard Contractual Clauses (SCCs)

We put the appropriate Saudi Data & AI Authority (SDAIA) contractual transfer safeguard in place where the transfer mechanism requires it.

NEXT STEP

Need a Data Processing Agreement as a focused service or part of your Data Protection Officer (DPO) Office?

Share the Processor relationship, proposed agreement, processing scope and any available screening evidence. We can review or prepare the DPA as a focused engagement or connect it to the wider third-party governance support you need.

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