On 5 September 2021, the UAE announced plans to introduce a new federal data protection law (“UAE Data Law”) in the coming weeks, its first-ever comprehensive data privacy and protection law to be issued.  The new law forms part of the UAE’s Projects of the 50, a set of economic and developmental initiatives designed to mark the country’s 50th anniversary, and launches the next phase of the UAE’s growth.

The UAE Data Law was developed in consultation with major technology companies. H.E. Omar Bin Sultan Al Olama, Minister of State for Artificial Intelligence, has stated that “every single data law on the planet” was considered when drafting the new legislation.  The new law aims to be a “global law” that will provide international companies with a smooth mechanism for cross-border transfers, as well as have a low cost of compliance for SMEs. Some aspects of the UAE Data Law will include:

  • the right to be forgotten, the right of access, the right of correction, and the right to be informed, all of which are already included in EU GDPR, Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) data protection laws;
  • consent obligations regarding marketing of data by companies seeking to monetize data;
  • minimal restrictions on cross-border data flows or references to sensitive or restricted data; and
  • provisions for a new national data privacy regulator.

The UAE Data Law is likely to be issued before the end of November 2021, prior to the country’s 50th anniversary.  Once enacted, the UAE Data Law might also provide an adequate level of protection for the purposes of data transfers from other regulated jurisdictions, including the DIFC and ADGM.

The UAE Data Law will not likely apply to data privacy and protection related to government data or health data, which will be covered by separate new or revised legal regimes.

We will continue to monitor these developments at Inside Privacy.

Photo of Julie Teperow Julie Teperow

Julie Teperow advises multinational clients on complex local and international regulatory, public policy, and corporate matters. She advises across a broad range of sectors, including life sciences, technology and consumer products. She has particular experience with regional cross-border compliance issues, helping clients navigate…

Julie Teperow advises multinational clients on complex local and international regulatory, public policy, and corporate matters. She advises across a broad range of sectors, including life sciences, technology and consumer products. She has particular experience with regional cross-border compliance issues, helping clients navigate regulatory frameworks and the practical issues arising when doing business in the Middle East and North Africa region.

Julie also has experience with government affairs in the GCC ‒ advising companies on commercial, trade and market access. She has expertise in advising companies on entering and dealing with issues particular to emerging markets.

In addition to regulatory compliance and government affairs, Julie assists clients with regulatory aspects of corporate and commercial transactions, including employment issues. She also acts as the firm’s representative for the Women’s Forum for the Dubai office.

Photo of Azumah Cofie Azumah Cofie

Azumah Cofie is a lawyer in the Project Development and Finance Practice Group in London. He joined Covington as a trainee solicitor in 2020 and trained in the firm’s London and Dubai offices. He has experience advising borrowers, sponsors and lenders on the…

Azumah Cofie is a lawyer in the Project Development and Finance Practice Group in London. He joined Covington as a trainee solicitor in 2020 and trained in the firm’s London and Dubai offices. He has experience advising borrowers, sponsors and lenders on the development and financing of international energy and infrastructure projects.

Azumah is also a member of the firm’s Africa Practice Group and a co-lead of the Multicultural Network affinity group in London.