EGYPT Law and Practice Contributed by: Ibrahim Shehata, Hesham Kamel, Mohamed Abed and Omar Selim, Shehata & Partners
3. Requirements for the Protection and Processing of Non-Personal Data 3.1 Objectives and Scope of Data Regulation There is no general legal framework governing the protection or processing of non-personal data, simi - lar to the EU Data Act. The PDPL, its Regulations and the mandate of the Center are limited to personal data and do not extend to non-personal data. Adoption and Scope of the Open Data Policy Against this backdrop, Egypt has adopted an Open Data Policy (the “Policy”), issued by the National Council for Artificial Intelligence in 2025. The Policy defines open data as non-sensitive and non-personal data held by the governmental authorities and made available in an electronic-readable format, subject to minimal restrictions on its use or reuse. However, the Policy serves as a transitional regulatory instrument, pending the issuance of a comprehensive data gov - ernance law, its executive regulations, and the accom - panying data classification framework; the Policy is expected to be superseded and replaced by such law, once enacted. In this context, the Policy aims to support and pro - mote the development of innovative digital services. It specifically regulates the availability of data not falling within the categories of personal data, data related to national security, and trade secrets. Once enacted, the anticipated data governance law and its executive regulations are expected to designate the Egyptian Data Governance Authority (which is not yet established) as the central co-ordinating authority, responsible for setting priorities, monitoring compli - ance, overseeing the availability of public data sets, and approving relevant strategic initiatives. Overall, the Policy primarily addresses data access, use and reuse, rather than establishing rules govern - ing the processing of non-personal data. Internet of Things Regulatory Framework The NTRA issued a dedicated internet of things (IoT) regulatory framework in Egypt in January 2022, set - ting out the key rules and procedures governing the provision and use of IoT services and expressly pro - viding that the regulatory framework shall be imple -
mented in accordance with, and abide by the terms of, the PDPL, its Regulations, the Cybercrimes Law and the Telecommunications Law. In addition, the frame - work expressly prohibits any user of IoT services from transferring IoT-related data outside Egypt. In practice, IoT services may involve the access and sharing of data with the governmental authori - ties. Where such IoT-generated data does not relate to identified or identifiable individuals and does not qualify as sensitive data, it may be classified as non- personal, non-sensitive data. In such cases, access to and reuse of this data would be expected to fall within the scope of the Policy. By way of example, data generated by the IoT sen - sors installed by a government authority to monitor traffic flow, air quality or energy consumption levels, where the data is aggregated and does not allow for identifying individuals, would generally be considered non-personal and non-sensitive, and may therefore be made available in accordance with the Policy. Regulatory Framework for Cloud Services and Data Centres With respect to cloud computing, Egypt has a multi- layered regulatory and policy approach. The NTRA has established a regulatory framework governing the establishment and operation of data centres and the provision of cloud computing services in Egypt. This framework aims to attract large-scale data centres and cloud service providers, and to support Egypt’s broader digital transformation objectives. Cloud First Policy In parallel, the Supreme Council of Digital Society (SCDS), formed under President Decree No 501 of 2017, adopted the Cloud First Policy in 2024. This guiding non-binding policy was developed and imple - mented in alignment with international standards and best practices. The Cloud Policy is aligned with Egypt’s Vision 2030 and the Digital Egypt Strategy, and aims to high - light the pivotal role of cloud computing in building a secure and sustainable digital society. The Cloud Policy also contributes to promoting the adoption of cloud computing services across both the public and
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