DPO Arabia

DATA SHARING AGREEMENT (DSA)

Document controller-to-controller data sharing with clear purpose and accountability.

DPO Arabia structures Controller-to-Controller Data Sharing Agreements around the permitted disclosure basis, purpose, Personal Data scope, recipient responsibilities, onward use, retention, security, transparency and any cross-border requirements relevant to the arrangement.
We first confirm that the disclosure can proceed under the Saudi Personal Data Protection Law (PDPL), then document how the approved Controller-to-Controller sharing arrangement will operate through the Data Sharing Agreement (DSA).

REGULATORY BASIS

KSA PDPL Articles 15 and 16, and Implementing Regulation Article 20

OPERATING FOCUS

Disclosure basis, purpose, Personal Data scope, recipient role, permitted use, onward disclosure, retention, security, transparency and transfer implications

OUTCOME

A documented Controller-to-Controller sharing arrangement aligned to the underlying disclosure decision and retained 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 Controller-to-Controller disclosure

02

Recurring Personal Data sharing

03

New strategic or business partner

04

Public authority or regulated disclosure arrangement

05

Material change in sharing purpose or scope

06

Recipient outside Saudi Arabia

WHY IT MATTERS

Put the disclosure decision and the sharing controls into one governed arrangement.

We establish the permitted disclosure condition, specific purpose, necessary Personal Data, recipient responsibilities, privacy protections and record-keeping requirements before translating the approved arrangement into a DSA. This keeps the agreement anchored to a disclosure decision that has actually been assessed.

The agreement should follow the disclosure assessment, not replace it. First establish that the sharing is permitted, then document how the parties will operate it.

WHAT DPO ARABIA DELIVERS

Turn an approved disclosure into a governed Controller-to-Controller arrangement.

The service connects the disclosure decision with the agreement terms, responsibilities and evidence needed to keep the sharing controlled over time.

01

Disclosure scope & purpose schedule

Document the parties, Personal Data, Data Subjects, disclosure purpose, frequency, method and intended recipient use.

02

Disclosure basis assessment

Identify which permitted disclosure condition applies and any restrictions or dependencies affecting reliance on it.

03

Controller responsibility framework

Define each party’s independent responsibilities, contact points, transparency obligations and accountability after disclosure.

04

Permitted use, retention & onward-disclosure controls

Set boundaries around use, retention, onward sharing and other processing by the recipient.

05

Security, incident & rights cooperation

Establish appropriate security expectations and cooperation where shared Personal Data is affected by an incident or Data Subject request.

06

Transfer & governance linkage

Connect the DSA to the Record of Processing Activities (RoPA), disclosure record, Privacy Notice and any Transfer Impact Assessment (TIA)/Transfer Risk Assessment (TRA) or transfer safeguard where the recipient or access is outside Saudi Arabia.

HOW WE WORK

Move from disclosure assessment to an executed, evidence-linked DSA.

The four-stage workflow keeps the disclosure basis, agreement terms and supporting governance records connected from initial scoping through execution.

01

Map the disclosure

Identify the parties, Personal Data, Data Subjects, purpose, frequency, method, recipient use and transfer context.

02

Assess permissibility

Determine the applicable disclosure condition, restrictions, minimisation requirements and transparency implications.

03

Structure the agreement

Document responsibilities, permitted use, security, retention, onward disclosure, rights cooperation and transfer provisions where relevant.

04

Execute & evidence

Finalise the agreement and connect it to the RoPA, disclosure record, Privacy Notice and future review triggers.

EVIDENCE YOU RETAIN

Keep the agreement and the disclosure decision behind it together.

The evidence set shows why the disclosure was permitted, what the parties agreed and how the arrangement connects to the Controller’s wider PDPL records.

KSA PDPL REGULATORY CONTEXT

Connect the DSA to the underlying disclosure requirements.

We use the KSA PDPL disclosure conditions, restrictions and documentation requirements to determine whether sharing may proceed and then structure the DSA around the approved Controller-to-Controller arrangement.

Saudi PDPL Article 15 – Permitted Personal Data Disclosure Conditions

Establishes the circumstances in which Personal Data may be disclosed, including consent and other specified PDPL conditions.

Saudi PDPL Article 16 – Prohibited Personal Data Disclosures Despite Exceptions

Sets circumstances in which disclosure must not proceed even where an Article 15 condition could otherwise apply.

PDPL Implementing Regulation Article 20 – Disclosure of Personal Data

Requires a clear disclosure purpose, privacy protection, data minimisation and documentation of disclosure operations, including dates, methods and purposes.

RELATED DPO GUIDE

Need deeper context on structuring Personal Data processing and sharing terms?

The related DPO Guide provides deeper context on defining processing scope, responsibilities, safeguards, assistance, deletion and transfer terms when Personal Data is governed through contractual arrangements.

THIRD PARTIES, CONTRACTS & TRANSFERS

What a KSA PDPL DPA Needs to Cover

USE WHEN: translating Personal Data processing responsibilities and safeguards into clear contractual terms.

RELATED THIRD PARTIES, CONTRACTS & TRANSFERS SERVICES

Connect the DSA into the wider disclosure governance lifecycle.

Where the requirement extends beyond this service, we connect the work to the related services that record the disclosure, align the underlying processing record and manage cross-border requirements where the recipient or access is outside Saudi Arabia.

01

DISCLOSURE EVIDENCE

Disclosure & DSA Register

We maintain a traceable record of disclosures, sharing arrangements, legal conditions and supporting agreements.

02

CONNECTED CONTROL

Record of Personal Data Processing Activities (RoPA)

We can support this work when the Record of Personal Data Processing Activities (RoPA) control needs to be connected to the wider evidence and operating workflow.

03

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.

NEXT STEP

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

Share the proposed disclosure, recipient, purpose, Personal Data scope and any existing agreement or assessment. We can structure the DSA as a focused engagement or connect it to the wider disclosure and transfer governance support you need.

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