A common issue multinational companies (“MNCs”) have to deal with in the evolving privacy landscape is how and when they can lawfully transfer personal information across borders. MNCs doing business in the UAE now have a new consideration in the form of the new UAE Data Protection Law when doing so.
This Update is intended to provide a high-level overview of the respective data transfer mechanisms under the Federal Law No. 45 of 2021 Regarding the Protection of Data, issued on 20 September 2021 (“UAE Data Protection Law), the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), including as retained in the United Kingdom, and the California Consumer Privacy Act of 2020 (“CCPA”), so MNCs in the UAE can consider how they may need to change the way in which they transfer data from the UAE into the EU and California.
We are also following the ongoing development of a new data protection law in the Kingdom of Saudi Arabia and will be releasing a follow-up alert on how that law is taking shape.
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