Saudi PDPL Audit Checklist: 12 Steps to Ensure 100% Compliance

The Saudi PDPL audit checklist is necessary for every company located in the KSA that operates in personal data protection. While the Personal Data Protection Law was initiated by the Saudi Data and AI Authority (SDAIA), businesses have to comply with such requirements or face legal actions and repercussions.

This detailed guide provides 12 key actions that must be taken by businesses to comply with all PDPL requirements, with a clear PDPL compliance guide to confirm data protection procedures conform to regulatory requirements.

Whether starting on the compliance path or confirming existing policies, adhering to this audit checklist should help you stay at 100% compliance with KSA’s changing data protection environment.

Why Is the Saudi PDPL Important?

The KSA data protection regime under the PDPL defines the manner in which personal data shall be collected, stored, processed, and transferred. The PDPL imposes compulsory requirements, unlike the older guidelines on both public and private bodies, that bring personal privacy under a safe vision of banning the misuse of data.

These enforcement powers and financial regulators allow PDPL to align Saudi Arabia with international data protection standards like GDPR.

The 12-Step Saudi PDPL Audit Checklist

Use the following steps to implement or review your organization’s Saudi PDPL audit checklist:

1. Appoint a Data Protection Officer (DPO)

One of the first steps towards compliance is the appointment of a DPO or designated compliance leader. The DPO should:

Oversee PDPL compliance across departments
Serve as a liaison with SDAIA.
Conduct internal audits
Train staff on privacy practices

The absence of a DPO could hinder an effective response to data breaches or inquiries from authorities

Need help appointing a DPO? KSA PDPL Certification Scooply can guide you through the certification journey.

2. Maintain a Personal Data Inventory

Creating a data inventory is critical for identifying what personal data you collect, process, store, and share. Your inventory should include:

Data categories (e.g., identity, financial, biometric)
Purpose of processing
Storage locations (on-premise or cloud)
Legal basis for processing

This step forms the backbone of your data protection strategy and is often required during regulatory assessments.

3. Establish Legal Basis for Data Processing

Under PDPL, every data activity must be justified with a lawful basis. These can include:

Consent from the data subject
Contractual necessity
Legal obligations
Public interest

Audit your existing data operations to ensure each has a valid basis. Keep records of how and when consent was obtained, especially for sensitive data.

4. Review and Update Privacy Policies

Outdated or vague privacy policies can result in compliance failures. Your privacy policy must:

Be written in clear Arabic (and optionally, English)
Disclose data collection methods.
Explain the purpose and duration of data retention.
Provide contact information for the DPO.

For KSA, policies must be culturally and linguistically adapted. Use the Saudi PDPL Compliance Roadmap to tailor your approach effectively.

5. Implement Consent Management Systems

Consent must be explicit and revocable. An effective consent management system allows users to:

Opt-in to data collection
Withdraw consent at any time.
Understand what data is being collected and why

For businesses operating cross-border, refer to PDPL Cross-Border Compliance to understand additional rules for data transfer.

6. Create Data Subject Rights Procedures

Under PDPL, individuals have rights, including:

Right to access their data
Right to correct inaccurate data.
Right to delete their data.
Right to object to processing.

Ensure you have formal procedures and response timelines to accommodate these requests, and train your teams accordingly.

7. Conduct Privacy Impact Assessments (PIAs)

Before launching new products or services that involve personal data, conduct a Privacy Impact Assessment (PIA). This assessment should:

Identify potential data privacy risks
Evaluate harm to individuals.
Recommend mitigation strategies

A thorough PIA also supports your compliance posture during audits or inspections.

8. Strengthen Cross-Border Data Transfer Controls

Cross-border data transfers are heavily regulated under PDPL. You must:

Justify the necessity for international transfer
Confirm the destination country provides adequate protection.
Use contracts or binding rules to safeguard data.

Learn more about navigating cross-border restrictions through this comprehensive PDPL cross-border guide.

9. Document Data Retention and Deletion Policies

KSA regulations require that data not be stored longer than necessary. You must define:

How long is personal data retained
Criteria for archiving or deleting data
Secure deletion procedures

Automate deletion and archiving policies using data governance tools to reduce the risk of over-retention.

10. Enforce Vendor and Third-Party Compliance

Vendors who process personal data on your behalf must also comply with PDPL. Ensure your contracts include:

Data processing agreements (DPAs)
Confidentiality clauses
Breach notification timelines

Assess vendor risk regularly, especially for cloud or IT service providers. Review Mobishastra PDPL compliance for real-world vendor alignment examples.

11. Train Employees on PDPL Requirements

PDPL compliance is a company-wide responsibility. Your audit checklist should include:

Regular staff training
Clear policies on data access and usage
Phishing and social engineering awareness

Align your training with recognized frameworks such as ISO 27001 for enhanced security posture.

12. Establish a Breach Notification Plan

In the event of a data breach, PDPL mandates prompt notification to SDAIA and affected individuals. Prepare your response plan with:

Defined severity levels
Roles and responsibilities
Communication templates
Incident logs and reporting tools

Time is critical during a breach. Automating incident detection and alerts can minimize the impact.

Saudi PDPL Audit Checklist in Action

Applying the Saudi PDPL audit checklist isn’t a one-time task—it’s an ongoing compliance journey. Organizations should schedule quarterly internal audits and annual third-party assessments. These periodic reviews help:

Identify gaps

Prevent regulatory fines
Maintain customer trust
Boost business resilience

For example, organizations seeking certification often turn to PDPL Certification with Scooply for streamlined audits and tailored documentation support.

Additional Tips for 100% PDPL Compliance

Here are bonus insights to strengthen your compliance program:

Use the KSA PDPL Overview as your foundation for compliance understanding.
Follow the latest updates through SDAIA’s self-assessment portals and resources.
For multinationals, compare requirements with UAE PDPL Compliance to harmonize regional
strategies.
Leverage tools like GetSahl for automation, document management, and compliance reporting.

Is PDPL Audit Mandatory in Saudi Arabia?

Yes, performing a PDPL audit is highly recommended and in some cases required, especially when organizations are handling large volumes of personal or sensitive data. SDAIA encourages businesses to self-assess through official tools like the PDPL Self-Assessment Portal.

Even if not explicitly mandated for all sectors, conducting regular audits:

Identifies compliance gaps
Protects against enforcement actions
Enhances organizational transparency

Penalties for Non-Compliance with PDPL in Saudi Arabia

Failing to comply with PDPL can result in:

Fines of up to SAR 5 million
Suspension of business operations
Criminal liability for certain violations
Revocation of licenses for repeated offenses

SDAIA has made it clear that enforcement will be active and strict. It’s better to proactively engage with certified solutions, such as those offered by GetSahl, to avoid these risks.

How Often Should PDPL Audits Be Conducted?

A good practice is:

Quarterly internal audits
Annual third-party audits
Immediate audits after a breach or data incident

These periodic reviews ensure operational compliance and adaptation to changing regulations.

Final Thoughts: Your Roadmap to Complete PDPL Compliance

100% compliance isn’t just something to check off legally—it’s a commitment to preserve the privacy and ethics of data. The Saudi PDPL audit checklist is an orderly and executable roadmap to execute this promise with ease.

These 12 steps can be very beneficial for your business security and scalability, as by complying with PDPL guidelines, your company can grow under KSA leadership by protecting the rightful data cycle.

Utilize channels like GetSahl for real-time audit software, certification support, and regulatory alerts. With the implementation of proper processes and attitudes, PDPL compliance is well within reach.

FAQs

What is the Saudi Arabia equivalent of GDPR?

The official equivalent of GDPR in Saudi Arabia is most likely PDPL, or the Personal Data Protection Law, which facilitates wider imposition of strict rules on any transfer of data.

How does PDPL influence Multinational companies?

Legally working companies that process Saudi residents’ personal data are required to abide by the regulations of PDPL to prevent any unnecessary blocking.

Can I transfer data outside of Saudi Arabia?

Yes, you can transfer data outside of Saudi Arabia, but according to certain rules and conditions, such as designing protection levels in the destination country.