An Intra Group Data Sharing Agreement is essential for corporate groups operating in the UAE who need to share personal data between different entities within their organization. This document becomes necessary when group companies need to transfer or share personal data while ensuring compliance with UAE Federal Decree-Law No. 45/2021, DIFC Data Protection Law No. 5 of 2020, ADGM Data Protection Regulations 2021, and other applicable regulations. The agreement addresses key requirements including data protection principles, security measures, breach notification procedures, and data subject rights. It is particularly important for groups with entities in different UAE jurisdictions (onshore/free zones) or those engaging in cross-border data transfers. The document should be reviewed and updated periodically to ensure continued compliance with evolving data protection regulations.
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Key Requirements PROMPT example:
Intra Group Data Sharing Agreement
"I need an Intra Group Data Sharing Agreement for our UAE-based retail group with 5 subsidiaries, covering customer and employee data sharing between our Dubai mainland entity and DIFC branches, to be implemented by March 2025."
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1. Parties: Identification of the group entities participating in the data sharing arrangement
2. Background: Context of the agreement, group structure, and purpose of data sharing arrangements
3. Definitions: Definitions of key terms including Personal Data, Processing, Controller, Processor, Applicable Laws, Group Companies
4. Scope and Purpose: Detailed description of the data sharing activities covered and their legitimate purposes
5. Roles and Responsibilities: Clear designation of roles (controller/processor) for each party and associated responsibilities
6. Data Protection Principles: Commitment to core data protection principles under UAE law including lawfulness, fairness, and transparency
7. Legal Basis for Processing: Identification of legal grounds for data sharing under UAE law
8. Security Measures: Technical and organizational measures required for data protection
9. Data Subject Rights: Procedures for handling data subject requests and ensuring rights under UAE law
10. Breach Notification: Procedures for handling and reporting data breaches within the group
11. Confidentiality: Confidentiality obligations for all parties handling the shared data
12. Term and Termination: Duration of the agreement and termination provisions
13. Governing Law and Jurisdiction: Specification of UAE law as governing law and jurisdiction for disputes
1. Cross-Border Transfers: Required if data will be transferred outside the UAE, specifying transfer mechanisms and safeguards
2. Sector-Specific Requirements: Required for regulated sectors such as healthcare or financial services
3. Free Zone Compliance: Required if any party operates in DIFC or ADGM, addressing specific free zone requirements
4. Data Protection Officer: Required if any party is required to appoint a DPO under applicable laws
5. Audit Rights: Optional section detailing audit procedures and requirements
6. Sub-processing: Required if any party will engage sub-processors for data processing activities
7. Insurance: Optional section specifying insurance requirements for data protection
8. Cost Allocation: Optional section detailing how costs related to data protection compliance will be shared
1. Schedule 1 - Participating Group Entities: List of all group entities participating in the data sharing arrangement, including their roles and contact details
2. Schedule 2 - Categories of Data: Detailed description of personal data categories being shared and purposes of sharing
3. Schedule 3 - Technical and Organizational Measures: Detailed security measures and controls implemented by all parties
4. Schedule 4 - Transfer Mechanisms: Details of mechanisms used for international transfers if applicable
5. Schedule 5 - Processing Activities: Register of processing activities covered by the agreement
6. Appendix A - Standard Contractual Clauses: SCCs for international transfers if required
7. Appendix B - Data Subject Request Procedure: Detailed procedures for handling data subject rights requests
8. Appendix C - Breach Response Plan: Detailed procedures for responding to data breaches
Authors
Relevant legal definitions
Clauses
Relevant Industries
Financial Services
Healthcare
Technology
Retail
Manufacturing
Professional Services
Real Estate
Energy
Telecommunications
Transportation and Logistics
Education
Hospitality
Media and Entertainment
Relevant Teams
Legal
Compliance
Information Technology
Information Security
Risk Management
Data Protection
Corporate Governance
Operations
Privacy
Regulatory Affairs
Relevant Roles
Chief Legal Officer
Data Protection Officer
Chief Privacy Officer
Chief Information Security Officer
Legal Counsel
Compliance Manager
IT Director
Risk Manager
Information Security Manager
Operations Director
Chief Technology Officer
Group General Counsel
Privacy Manager
Corporate Secretary
Head of Compliance
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