Standards Comparison

    UAE PDPL

    Mandatory
    2022

    UAE federal law for onshore personal data protection

    VS

    AS9110C

    Mandatory
    2016

    International standard for aviation maintenance quality management systems.

    Quick Verdict

    UAE PDPL mandates privacy protections for personal data across UAE onshore entities, while AS9110C is a voluntary QMS standard for aviation MROs ensuring airworthiness. Organizations adopt PDPL for legal compliance, AS9110C for certification and market access.

    Data Privacy

    UAE PDPL

    Federal Decree-Law No. 45 of 2021 Concerning Personal Data Protection

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Mandates DPOs and DPIAs for high-risk processing
    • Extraterritorial scope targeting UAE residents' data processors
    • Requires records of processing for all controllers/processors
    • Embeds GDPR-like principles with risk-based accountability
    • Strict breach notifications to UAE Data Bureau
    Quality Management

    AS9110C

    AS9110C Quality Management Systems for Aviation Maintenance Organizations

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Risk-based thinking in operational planning
    • Configuration management and traceability controls
    • Counterfeit and suspect parts prevention
    • Product safety and human factors integration
    • Maintenance release and airworthiness requirements

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    UAE PDPL Details

    What It Is

    UAE PDPL (Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data) is a comprehensive federal regulation establishing onshore UAE's first economy-wide personal data framework. Effective 2 January 2022, it governs processing by controllers/processors via a risk-based approach, embedding principles like fairness, purpose limitation, minimization, accuracy, security, and accountability.

    Key Components

    • Core processing controls (Articles 4-5: lawful bases, consent rules)
    • Data subject rights (Articles 13-19: access, portability, erasure, objection to profiling)
    • Governance mandates (DPOs, DPIAs for high-risk; RoPAs for all)
    • Security/breach rules (Article 20, 9), cross-border transfers (Articles 22-23) Compliance enforced by UAE Data Office; no certification but administrative penalties up to AED 5 million.

    Why Organizations Use It

    Mandated for onshore entities processing UAE residents' data; extraterritorial reach. Drives trust, aligns with GDPR for multinationals, mitigates fines/reputational risks, enables secure digital economy participation.

    Implementation Overview

    Phased program: gap analysis, data inventory/RoPA, DPIAs, security hardening, rights workflows, vendor DPAs. Applies to private sector (excl. free zones/health/banking); 12-18 months typical via multidisciplinary teams.

    AS9110C Details

    What It Is

    AS9110C (AS9110:2016 Rev C) is an international quality management system (QMS) standard for aviation maintenance organizations (MROs), repair stations, and continuing airworthiness providers. It builds on ISO 9001:2015 with aerospace-specific requirements, using a risk-based thinking approach via Annex SL high-level structure and PDCA cycle. Scope covers maintenance, repair, overhaul, emphasizing safety and regulatory alignment.

    Key Components

    • Core clauses (4–10): context, leadership, planning, support, operation, evaluation, improvement.
    • Aviation additions: configuration management, counterfeit parts prevention, product safety, human factors, traceability, preservation.
    • Built on ISO 9001 baseline; no fixed control count, but requires documented information.
    • Certification model via IAQG OASIS, with internal audits and management reviews.

    Why Organizations Use It

    • Meets customer/OEM contracts and regulatory harmony (FAA/EASA Part 145).
    • Mitigates safety risks, ensures airworthiness, boosts on-time delivery.
    • Gains market access, reduces rework, enhances stakeholder trust.

    Implementation Overview

    • Phased: gap analysis, process design, training, audits (6–12 months typical).
    • Applies to MROs globally; requires certification audits (Stage 1/2).

    Key Differences

    Scope

    UAE PDPL
    Personal data processing, rights, transfers
    AS9110C
    Aviation maintenance QMS, airworthiness

    Industry

    UAE PDPL
    All onshore UAE sectors, private entities
    AS9110C
    Aerospace MRO organizations globally

    Nature

    UAE PDPL
    Mandatory federal privacy law
    AS9110C
    Voluntary quality certification standard

    Testing

    UAE PDPL
    DPIAs for high-risk, breach notifications
    AS9110C
    Internal audits, certification audits

    Penalties

    UAE PDPL
    Administrative fines up to AED 5M
    AS9110C
    Loss of certification, no legal fines

    Frequently Asked Questions

    Common questions about UAE PDPL and AS9110C

    UAE PDPL FAQ

    AS9110C FAQ

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