Data Protection and Privacy 2025

QATAR Law and Practice Contributed by: Alex Saleh, Asad Ahmad, Dean Jaloudi and Jehan Saleh, GLA & Company

The PDPPL does not apply to personal data that is used as statistical data and may also not apply to personal data that is processed in private or family settings. Furthermore, the QFC Regula - tions provide for a definition of sensitive data to encompass data relating to criminal convictions as well as to biometric and genetic data. The QFC Regulations further stipulate that there must be a particular and specific permit for the processing of sensitive data. Article 12 of the Regulations states that the data controller must apply in writing to the DPO, setting out: • the identity and contact details of the data controller; • the name, address, telephone number and email address of the person within the data controller responsible for making the applica - tion for the permit; • a description of the processing of sensitive personal data for which the permit is being sought, including a description of the nature of the sensitive personal data involved; • the purpose of the proposed processing of the sensitive personal data; • the classes of data subjects being affected; • the identity of any person to whom the data controller intends to disclose the sensitive personal data; • to which jurisdictions (if known) such sensi - tive personal data may be transferred outside the QFC; and • a description of the safeguards put in place by the data controller, to ensure the security of the sensitive personal data. Special Overview of Children’s Websites The PDPPL obliges all operators of websites targeting children to post specific notifications to the users. Thus, the prior explicit consent of a child’s guardian would be taken. Despite the

broad coverage of such websites, in practice this is widely viewed as engulfing various cat - egories of digital media, including social media applications. Internet and Online Streaming Moreover, as regards the internet and online streaming, the PDPPL as well as the Qatari Civil Code provide for a clear restriction against: • hate speech (and provide for its defusal); • any propaganda that concerns political ties; or • any disrespect against the Emir, any other political or governmental figure, or any reli - gious figure. Specific Overview of the Banking Sector Banks operating in Qatar must take into con - sideration precautionary measures, as follows: • raising awareness internally and among their service providers; • conducting due process and reviewing inter - nal policies, disclaimers, consents or agree - ments, and ensuring their compliance with the PDPPL; • conducting marketing and implementing technical support mechanisms able to answer any customer concerns; • conducting regular training and keeping employees up to date; and • reviewing all security measures implemented by the bank and the service providers, and assessing whether any further steps can be taken or investments made to protect cus - tomer data. Specific Overview of the QFC The QFC Regulations enhance the rights of data subjects with respect to their personal data, as follows:

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