Data Protection and Privacy 2025

EGYPT Law and Practice Contributed by: Ibrahim Shehata, Tasneem El-Naggar and Safa Rabea, Shehata & Partners

on the development, deployment and manage - ment of AI systems. Although there are no formal AI regulations, the PDPL indirectly governs AI by imposing safe - guards for the collection, processing and reten - tion of personal data. This creates an implicit interplay between data protection laws and the use of AI, ensuring that AI systems comply with existing privacy and security standards. The Egyptian Charter, while non-binding, reflects the government’s commitment to fostering responsible AI use. It positions Egypt to align with global standards and lays the groundwork for future regulatory developments to address specific challenges related to AI. Recent Trends in Privacy Litigation in Egypt Privacy litigation in Egypt remains in its early stages due to the relatively recent enactment of the PDPL. While enforcement mechanisms are still developing, a clear trend is emerging in cases where individuals’ personal data has been violated or misused through communica - tion devices, reflecting the judiciary’s focus on safeguarding privacy rights. Case example: dissemination of private information In Case No 19754 of 93 Judicial Year, dated 10 September 2024, the appellant was convicted of violating a victim’s privacy by disseminating private information and intentionally disturbing her by using communication devices. She chal - lenged the judgment, citing insufficient reason - ing, misinterpretation of evidence and a violation of her right to defence. The appellant argued that 2. Privacy Litigation 2.1 General Overview

the judgment lacked clarity and failed to outline the crimes and evidence adequately, and should have been dismissed due to the plaintiff’s lack of standing. She also contended that her actions constituted permissible criticism and claimed the court ignored findings from an administra - tive investigation. The Court of Cassation rejected the appellant’s claims, affirming that the judgment was legally sound, detailed and adequately reasoned. It upheld the conviction, dismissed objections to the admissibility of the case, and ruled that the evidence supported the findings. The court also dismissed the appeal and ordered the forfeiture of the appellant’s bail, emphasising the impor - tance of privacy rights and the clarity of judicial This case illustrates important aspects of Egypt’s emerging privacy litigation landscape, including: • the recognition of privacy violations – the court’s handling of this case highlights the growing seriousness with which privacy breaches involving personal information dis - semination are being addressed; and • judicial clarity and accountability – the Court of Cassation reinforced the need for clear, detailed reasoning in judgments related to privacy violations, ensuring accountability for misuse of personal data. reasoning in such cases. Significance of the case Privacy litigation in Egypt is gradually evolving, with courts increasingly addressing violations of personal data. Recent cases exemplify the judiciary’s commitment to protecting privacy rights, ensuring accountability for privacy viola - tions, and upholding procedural fairness in such cases.

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