UAE PDPL
UAE federal regulation for personal data protection onshore
ISO 27018
Code of practice for PII protection in public clouds.
Quick Verdict
UAE PDPL mandates personal data protection for onshore entities, enforcing rights and security via law. ISO 27018 provides voluntary cloud privacy controls for processors. UAE firms comply legally; cloud providers adopt ISO for global trust and audits.
UAE PDPL
Federal Decree-Law No. 45 of 2021 on Personal Data Protection
Key Features
- Mandatory Records of Processing for controllers/processors
- Extraterritorial scope for foreign entities targeting UAE data
- Risk-based DPO appointment for high-risk processing
- DPIAs required for new technologies and sensitive data
- GDPR-aligned data subject rights and transparency obligations
ISO 27018
ISO/IEC 27018:2025 Code of practice for PII protection
Key Features
- Privacy controls for PII in public cloud processors
- Subprocessor transparency and location disclosures
- Prohibits secondary PII use without consent
- Breach notification to customers required
- Supports data subject rights fulfillment
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 with a risk-based approach, mandating measures proportionate to risks like large volumes or new technologies.
Key Components
- Core principles: fairness, purpose limitation, minimization, accuracy, security, storage limitation.
- Obligations: lawful bases (consent primary), Records of Processing Activities, DPO for high-risk, DPIAs.
- Data subject rights: access, portability, correction, erasure, objection, automated decisions.
- Breach notification, cross-border transfers via adequacy or safeguards. No certification; compliance via records and audits.
Why Organizations Use It
Mandated for onshore private sector (excl. free zones, gov't, health/banking), it ensures legal compliance, reduces breach risks, builds trust, aligns with GDPR for multinationals, enables secure digital economy participation.
Implementation Overview
Phased: discovery/gap analysis, design/remediation (policies, tools, training), operationalization (DPO, rights workflows), monitoring. Applies to all sizes processing UAE data; involves data mapping, vendor controls, security hardening.
ISO 27018 Details
What It Is
ISO/IEC 27018:2025 is an international code of practice extending ISO/IEC 27001 and ISO/IEC 27002 specifically for protecting personally identifiable information (PII) processed by public cloud service providers (CSPs) acting as PII processors. First published in 2014 and updated in 2019 and 2025, it employs a risk-based approach to address cloud-specific privacy challenges like multi-tenancy, subprocessors, and cross-border transfers.
Key Components
- ~25–30 additional privacy-specific controls across organizational, people, physical, and technological themes.
- Core principles: consent, purpose limitation, data minimization, accuracy, retention limits, transparency, accountability, security safeguards.
- Integrated into ISO 27001 ISMS; evaluated during 27001 audits, not standalone certification.
Why Organizations Use It
- Builds trust with customers, accelerates procurement via auditable assurances.
- Aligns with GDPR Art. 28, HIPAA; supports processor obligations.
- Reduces risk, procurement friction, improves cyber insurance; competitive differentiation for CSPs.
Implementation Overview
- Gap analysis, integrate into Statement of Applicability; develop subprocessor transparency, breach notification.
- Suited for CSPs all sizes/industries; requires third-party audits tied to annual ISO 27001 surveillance.
Key Differences
| Aspect | UAE PDPL | ISO 27018 |
|---|---|---|
| Scope | Personal data processing in onshore UAE | PII protection in public cloud processors |
| Industry | Onshore private sector, UAE-specific | Cloud service providers, global applicability |
| Nature | Mandatory federal law with penalties | Voluntary code of practice, ISO 27001 extension |
| Testing | Records, DPIAs, DPO for high-risk | ISO 27001 audits with privacy controls |
| Penalties | Administrative fines, criminal liability | Loss of certification, no legal penalties |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about UAE PDPL and ISO 27018
UAE PDPL FAQ
ISO 27018 FAQ
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