Scale, complexity, and cross-border operations - PDPL does not exempt any of it

Saudi Arabia's oil and gas sector operates at a scale and complexity that few industries match. Large permanent workforces, rotating shift contractors, joint venture partners, and an extensive vendor ecosystem all generate significant volumes of personal data — HR records, biometric site access, health and safety files, and contractor identity documentation — processed across multiple systems, sites, and often multiple jurisdictions. With PDPL fully enforced since September 2024, operators and their service companies face clear obligations around how this data is collected, governed, transferred, and protected — obligations that most have not yet systematically addressed.

Key challenges

  • Large, multinational workforces with biometric site access, health surveillance records, and occupational safety data that fall under the PDPL's sensitive data provisions
  • Joint venture structures and international operator partnerships creating cross-border personal data flows without SDAIA-recognised transfer safeguards in place
  • Extensive contractor and vendor networks handling employee and site personnel data under contracts that predate the PDPL and contain no data protection obligations
  • Operational technology environments — including connected field devices and remote monitoring systems — increasingly capturing data linked to identifiable individuals without a governance framework
  • No formal DPIA process for high-risk processing activities such as workforce health monitoring, biometric access control, or large-scale employee surveillance systems

How RSM Can Help

We deliver an oil and gas-specific PDPL gap assessment covering your HR and workforce systems, contractor data management processes, joint venture data sharing arrangements, and operational technology environment — producing a prioritised compliance roadmap tailored to the scale and structure of your operations. We develop data processing agreements for your contractor and vendor network, consent and retention frameworks for your workforce data, and DPIA processes for high-risk operational activities. Our DPO as a Service provides designated SDAIA and NDMO contact, workforce DSAR management, and 72-hour breach notification coverage — giving your HR, legal, and HSE teams a clear compliance framework without adding operational burden.