Data Protection and Privacy 2025

SAUDI ARABIA Law and Practice Contributed by: Alex Saleh, Asad Ahmad, Shahad Al Humaidani and Khaled Al Khashab, GLA & Company

years for the unauthorised disclosure or publi - cation of sensitive data with intent to harm the data subject, or for personal gain. Further, an SAR5 million fine shall be imposed on every per - son with a special natural or legal capacity who violates any of the provisions of the PDPL. The fine penalty may be doubled in the event of a repeat violation, even if it results in exceeding its maximum limit, provided that it does not exceed double this limit. Given the recent implementation of the PDPL, there is limited publicly available information regarding notable administrative proceedings or fines imposed by the SDAIA to date. PDPL cas - es are expected to occur in the coming years, which will provide clearer insights into the regu - latory landscape and the practical application of the PDPL. 1.5 AI Regulation In September 2024, the SDAIA published the AI Adoption Framework, offering a guiding frame - work that provides a comprehensive roadmap for the adoption of AI in all sectors. This frame - work represents a strategic step towards build - ing a knowledge-based society founded on innovation and continuous development. Its goal is to provide necessary guidance and instruc - tions, outline critical steps and procedures, and align with best practices to ensure optimal and responsible AI adoption, thus achieving suc - cessful milestones in the transformation towards AI within the ecosystem. In September 2023, the SDAIA published the first version of its AI Ethics Principles. These principles were issued and published with the aim of: • supporting KSA’s efforts towards achieving its vision and national strategies related to

adopting AI technology, encouraging research and innovation, and driving economic growth for prosperity and development; • developing and establishing AI ethics poli - cies, guidelines, regulations and frameworks; • governing data and AI models to limit the negative implications of AI systems and potential threats; • helping entities adopt standards and ethics when building and developing AI-based solu - tions to ensure responsible use thereof; and • protecting the privacy of data subjects and their rights with respect to the collection and processing of their data. The AI Ethics Principles apply to all AI stake - holders designing, developing, deploying, imple - menting, using or being affected by AI systems within KSA, including (without limitation) pub - lic entities, private entities, non-profit entities, researchers, public services, institutions, civil society organisations, individuals, workers and consumers. Seven principles are addressed in the frame - work: • fairness; • privacy and security; • humanity; • social and environmental benefits; • reliability and safety; • transparency and explainability; and • accountability and responsibility. In addition, in November 2023 the government announced the establishment of the Internation - al Centre for Artificial Intelligence Research and Ethics, which aims to advance competencies and legislative frameworks in the field of AI and other advanced technologies.

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