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Personal Data Processing Agreement Template for United Arab Emirates

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Key Requirements PROMPT example:

Personal Data Processing Agreement

"I need a Personal Data Processing Agreement for my UAE-based healthcare technology company acting as a data processor for multiple hospitals, with specific provisions for handling sensitive medical data and cross-border transfers to our cloud servers in Europe starting March 2025."

Document background
A Personal Data Processing Agreement is essential whenever an organization (the data controller) engages another party (the data processor) to process personal data on its behalf in the UAE. This agreement is required under Federal Decree-Law No. 45 of 2021 and must detail the scope of processing activities, security measures, confidentiality obligations, and compliance requirements. It serves as a crucial document for ensuring legal compliance, establishing clear responsibilities, and protecting both parties' interests while safeguarding personal data. The agreement must address specific UAE requirements, including data localization rules, cross-border transfer restrictions, and breach notification obligations. It is particularly important given the UAE's enhanced focus on data protection and privacy rights, with significant penalties for non-compliance.
Suggested Sections

1. Parties: Identification of the data controller and data processor, including full legal names, registration details, and addresses

2. Background: Context of the agreement, relationship between parties, and purpose of the data processing arrangement

3. Definitions: Definitions of key terms used in the agreement, aligned with UAE Federal Decree-Law No. 45 of 2021

4. Scope and Purpose of Processing: Detailed description of the personal data to be processed and the specific purposes for processing

5. Duration of Processing: Term of the agreement and processing activities, including conditions for termination

6. Obligations of the Data Processor: Processor's responsibilities including security measures, confidentiality, and processing restrictions

7. Obligations of the Data Controller: Controller's responsibilities including lawful instructions, assessments, and oversight

8. Data Security: Security measures required to protect personal data during processing

9. Confidentiality: Confidentiality obligations for personal data and processing operations

10. Sub-processing: Conditions and requirements for engaging sub-processors

11. Data Subject Rights: Procedures for handling data subject requests and ensuring rights under UAE law

12. Data Breach Notification: Procedures and timeframes for reporting and handling personal data breaches

13. Audit Rights: Controller's rights to audit processor's compliance and processor's obligations to demonstrate compliance

14. Data Transfer Requirements: Rules and safeguards for transferring personal data, especially outside the UAE

15. Termination and Data Deletion: Procedures for agreement termination and handling personal data post-termination

16. Governing Law and Jurisdiction: Specification of UAE law as governing law and jurisdiction for disputes

Optional Sections

1. Special Categories of Personal Data: Additional requirements when processing sensitive personal data such as health information

2. Data Protection Impact Assessment: Procedures for conducting DPIAs when required by processing activities

3. Insurance Requirements: Specific insurance obligations for data processing activities

4. Force Majeure: Provisions for handling events beyond parties' reasonable control

5. Business Continuity: Requirements for maintaining business continuity and disaster recovery

6. Compliance with Free Zone Regulations: Additional requirements if processing occurs within DIFC or ADGM

7. Data Protection Officer: Requirements if either party needs to appoint a DPO

8. Joint Controller Provisions: Additional provisions if the relationship involves joint controllership

Suggested Schedules

1. Schedule 1 - Processing Activities: Detailed description of processing activities, including categories of data subjects and personal data

2. Schedule 2 - Technical and Organizational Measures: Specific security measures and controls implemented to protect personal data

3. Schedule 3 - Approved Sub-processors: List of approved sub-processors and their processing activities

4. Schedule 4 - Transfer Mechanisms: Details of mechanisms used for international data transfers

5. Schedule 5 - Security Breach Response Plan: Detailed procedures for handling and reporting data breaches

6. Appendix A - Contact Details: Key contacts for both parties including emergency contacts and DPOs

7. Appendix B - Data Retention Periods: Specific retention periods for different categories of personal data

8. Appendix C - Audit Procedures: Detailed procedures for conducting compliance audits

Authors

Alex Denne

Head of Growth (Open Source Law) @ ¶¶Òõ¶ÌÊÓƵ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions



































Clauses




























Relevant Industries

Technology

Healthcare

Financial Services

E-commerce

Telecommunications

Education

Professional Services

Real Estate

Hospitality

Retail

Manufacturing

Transportation and Logistics

Media and Entertainment

Insurance

Government Services

Relevant Teams

Legal

Compliance

Information Security

IT

Risk Management

Procurement

Operations

Privacy

Vendor Management

Data Protection

Information Governance

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

Information Security Manager

IT Director

Chief Information Security Officer

Privacy Manager

Risk Manager

Procurement Manager

Vendor Management Officer

Chief Technology Officer

Operations Director

Chief Legal Officer

Contract Manager

Data Protection Specialist

Industries







Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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