Guide to Bahrain’s Personal Data Protection Law (PDPL)

In this guide:

1. Key provisions of Bahrain’s PDPL
2. Ensure business compliance
3. How Privacy Bee helps

Key provisions of Bahrain’s Personal Data Protection Law (PDPL)

The Personal Data Protection Law (PDPL) was enacted in 2018 and serves as the Kingdom of Bahrain’s primary data protection regulation. Although it took a year to become active in 2019, Bahrain’s PDPL supersedes any legislation in the country that contradicts its provisions. Prior to the creation of the PDPL, Bahrain had a patchwork of banking, telecommunications and labor laws the all included partial, incomplete protections for an individual’s personal data.

To enforce the PDPL, Bahrain created the Personal Data Protection Authority (PDPA) in 2022. The PDPA is charged with ensuring organizations comply with all personal data protection requirements and respect the rights created for data subjects, or those individuals whose data is being collected and processed.

In 2022 aligning with the creation of the PDPA, 10 resolutions were issued to supplement the PDPL. The PDPL at its core aims to regulate the processing of personal data in Bahrain and ensure the responsible protection of that data, applying to information processed by both private and public entities in the country and abroad. Adding to the PDPL, these resolutions cover:

1. Specific duties for Data Protection Officers (DPOs) within certain organizations and more information about related fees.
2. Technical and organizational measures required for businesses processing the data of any natural person who normally resides in Bahrain or has a place of business in Bahrain.
3. Notification procedures for data breaches and other specific events.
4. More detailed rules regarding data processing in general.
5. Rules regarding the processing of sensitive personal data, which is a subset of personal data including race, ethnicity, politics, religious beliefs, and more.
6. Rules regarding data subject rights, detailed below.
7. Rules regarding how publicly-available registers have to handle personal data carefully.
8. Rules regarding information about criminal events.
9. Rules regarding the submission of formal complaints to the PDPA.
10. Rules defining more stringent regulations for the transfer of personal data outside of Bahrain.

Altogether, these resolutions create a comprehensive framework for data protection in Bahrain. This legislation’s extraterritorial scope ensures data controllers must ensure responsible data handling practices even if they are located outside of the country. A critical piece of most global data privacy laws today, this stipulation—paired with more stringent regulations placed upon data transfers outside of the country—help close any loopholes a business might try to use to exploit the personal data of Bahraini residents. It also creates an obligation for organizations to secure the data subject’s consent at the time of data processing, ensuring the individual is informed of the purposes for data collection proactively. Data subjects can withdraw this consent at any time.

For the individual, the PDPL enumerates specific data subject rights which can be exercised at any time:

• Right to know if an organization is processing your data, with a mandate for the organization to provide a timely response.
• Right to access the information collected on the data subject and the reasons for the data processing.
• Right to object to direct marketing, which the data processor must communicate a notification for upon collection.
• Right to object to processing causing material or moral damage along with the right to object to decisions based on automated processing.
• Right to rectify incorrect information held by an organization.
• Right to block the collection of personal data by a specific data processor.
• Right to erase personal data currently held by an organization, especially if it is inaccurate, incomplete, outdated, or if was processed illegally.

Individuals have the option to submit formal complaints to the PDPA if they feel any of these rights have been violated by an organization. The PDPA can choose to levy fines or more serious penalties after an investigation finds any incidence of non-compliance. However, the goal is to help organizations proactively process data responsibly, which is why the PDPA continues to issue guidance notes to assist organizations.

Aside from the specific rights crafted for individuals, the PDPL was built upon the same key principles that characterize the best data privacy laws around the world. Those principles include a focus on lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy of information stored; storage limitations; integrity and confidentiality in data processing; and accountability for any company collecting personal data.

Overall, the PDPL is a significant step forward for data protection in Bahrain. It provides individuals with greater control over their personal data and encourages businesses to adopt responsible data management practices. Data protection laws of this nature are the foundation for building and maintaining trust in the digital economy.

Source: Bahrain’s Personal Data Protection Authority website

Ensure business compliance

To guide your organization to safely comply with the numerous obligations outlined in Bahrain’s PDPL, any company acting as a data controller needs to implement the appropriate technical and organizational processes to ensure compliance. This is not just for Bahrain’s regulations, but for most major international laws as well. While the language changes slightly from country to country, the core requirements are largely the same.

Before diving in, it’s important to note these obligations are also an opportunity. Consumers are increasingly skeptical of the organizations processing personal data today, and ethical data protection practices help differentiate your business and build brand equity. View this as a business opportunity, not a burden, and your bottom line is going to benefit in the short and long term.

Following these best practices can help organizations achieve and maintain compliance with Bahrain’s PDPL:

1. Conduct a data mapping exercise:

• Identify all personal data your organization collects, stores, and processes.
• Assess the purpose of data collection and ensure it aligns with PDPL principles.
• Determine the legal basis for processing each type of personal data.
• Map the data flow within your organization and identify third-party processors.

2. Implement data governance policies and procedures:

• Develop a data governance framework outlining data collection, storage, use, and disposal procedures.
• Establish data protection policies and procedures covering access controls, data breaches, and incident response.
• Appoint a Data Protection Officer (DPO) responsible for overseeing data protection compliance, especially if you’re a large organization or process a lot of sensitive data.

3. Obtain consent and manage data subject rights:

• Clearly communicate the purposes of data collection and obtain explicit consent from individuals before processing their data.
• Implement mechanisms for individuals to access, rectify, erase, restrict processing, and port their personal data easily.
• Respond to data subject requests promptly and within the legal timeframe.

4. Secure personal data proactively and effectively:

• Implement appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, loss, alteration, and destruction.
• Regularly review and update security measures to address emerging threats and vulnerabilities.
• Conduct security audits and penetration testing to identify and address vulnerabilities promptly.

5. Train employees and raise awareness:

• Provide all employees with training on data protection best practices and their individual responsibilities.
• Encourage employees to report any suspected data breaches or violations to the DPO or relevant manager immediately.
• Foster a culture of data privacy within the organization.

6. Stay updated:

• Monitor changes and updates to the PDPL along with any new guidance issued by the PDPA.
• Regularly review your data protection practices to ensure compliance with the latest regulations.
• Seek legal counsel if necessary to interpret the PDPL and ensure compliance.

7. Monitor third-party processors:

• When using third-party processors to handle personal data, ensure they comply with the PDPL.
• Include appropriate data protection clauses in contracts with third-party processors.
• Monitor the activities of third-party processors and ensure they comply with their contractual obligations.

8. Leverage technology solutions:

• Use data protection tools and technologies to automate compliance tasks, such as data discovery, classification, and access controls.
• Implement data encryption and other security measures to protect sensitive personal data.
• Consider using data anonymization or pseudonymization techniques where appropriate.

9. Implement data breach management procedures:

• Establish a data breach response plan outlining steps to identify, contain, and report data breaches promptly.
• Communicate data breaches to affected individuals and relevant authorities in accordance with the PDPL.
• Conduct post-breach reviews to identify root causes and improve data security practices.

10. Foster a culture of privacy:

• Encourage a culture of privacy within your organization by prioritizing data protection and respecting individual privacy rights.
• Demonstrate a commitment to transparency and accountability in your data handling practices.
• Build trust with individuals by being responsible stewards of their personal data.

By implementing these best practices, organizations can create a robust data protection framework that enables them to comply with the PDPL and protect the privacy rights of individuals. Remember, compliance is an ongoing process, so it’s crucial to regularly review and update your data protection practices to ensure they remain effective.

Done right, your organization will be shielded from expensive fines for noncompliance while building trust with consumers every step of the way.

How Privacy Bee helps

Protecting personal data while providing the required information about data usage to all users is imperative for businesses engaged in online service delivery today. New regulations sprout up around the world every day, requiring more stringent opt-in policies while granting consumers more rights. The public now has the ability to review and remove their personal data, increasing the accountability of every organization processing personal identifiable information (PII).

Despite the addition of new regulations in more countries every year, the responsibility still falls primarily on the individual to oversee, assess, update and delete (via DSAR request) their personal data wherever it may be collected and dispersed across the internet. This process becomes a massive undertaking when working to cover an entire organization, rendering it practically impossible for a single person or small team to manage without outside professional help. But it’s important. The identification and subsequent elimination of this data play a pivotal role in deterring cybercriminals from launching dangerous social engineering attacks against an organization.

That’s where Privacy Bee emerges as the solution, simplifying the time-consuming process of monitoring and eradicating employee personal data for business leaders. It’s especially effective for executives who are highly visible to the general public. Using sophisticated automation processes backed by an active human service team, Privacy Bee substantially reduces a company’s attack surface and mitigates the looming threat of a data breach. Social engineering attacks are the fastest-growing data breach threat, no matter how mature an organization’s cybersecurity program is today. If it isn’t already covered, then threat actors still have a way to target your organization’s most sensitive information.

Hopefully, you are already conducting risk assessments and vendor surveys. If so, kudos to you! However, it is still essential to recognize vendors are most susceptible to a breach via social engineering attacks relying on exposed data. Privacy Bee not only minimizes the proliferation of your organization’s data across the vast digital landscape but also extends its protection to vendors, helping you ensure third party partners do not serve as the weak link in your security defenses or put you at risk of noncompliance.

Who benefits from this? Who would do such a thing?

In the growing billion-dollar surveillance industry, Data Brokers and People Search Sites have assumed pivotal roles, reaping record-breaking profits by trading and transferring your organization’s information with obscure and uncontrollable entities. These entities then either publish this information or compile it all to sell on again, and suddenly your personal data can be easily found after a quick Google Search.

The consequences of private data exposure are far-reaching and pose significant threats if the information can be quickly obtained by malicious cybercriminals. If it’s as simple as a quick search to find you and your coworker’s information, then threat actors can launch cyberattacks at scale by targeting the most vulnerable team members with emotionally engaging messaging that turn even the most highly-trained professionals into victims. The only way to prevent this is by stopping the data flow at the source. The consequences are simply too costly to risk.

A solitary data breach leads to massive productivity losses, expensive remediation efforts, and recurring breach incidents. This isn’t new, and is a predicament that plagues the vast majority of businesses following an initial breach. Industry estimates state as many as 83% of organizations who experienced a data breach go on to experience multiple. That is staggering, and is exactly what Privacy Bee is fighting back against. The initial data breach sets off a chain reaction that inflicts short-term damage on your bottom line while eroding brand value and customer trust over time. Furthermore, there are ripple effects to consider, such as heightened employee turnover due to poaching.

Privacy Bee combats threat actors lurking beyond your organization’s perimeters. By meticulously pinpointing every location across the internet where sensitive data resides and swiftly purging it, Privacy Bee closes the data security gap. The service even encompasses dark web monitoring and provides timely data breach notifications if another company falls victim to an exploitation incident and potentially exposes your information in the process.

Our unwavering commitment is deeply rooted in the belief that privacy is an inalienable human right that transcends political discourse and negotiations. This is why Privacy Bee vigilantly monitors user data for security vulnerabilities while holding the surveillance industry accountable. We compel Data Brokers, People Search Sites, and more than 150,000 additional websites to expunge your stored data and opt out of further data collection to protect you, your family, and your entire organization.

Privacy Bee protection covers a wide range of potential threats, including:

• Data breaches
• Social engineering attacks
• Doxxing
• Identity theft
• Spam emails
• Telemarketing calls
• Cyberstalking
• Swatting
• Blackmail

Privacy Bee is a powerful tool for business leaders who want to protect their employee and customer data. In today’s world, where privacy is more important and harder to come by than ever, you need a trusted partner fighting to preserve your personal and organizational integrity.