The most sensitive data demands the most rigorous governance

Health data sits at the top of the PDPL's sensitive data hierarchy — requiring explicit consent, stricter processing conditions, and heightened security obligations. Saudi healthcare organisations operate across an increasingly complex data landscape: electronic health records, insurance claims, laboratory results, pharmaceutical trial data, and patient-facing digital platforms all fall squarely within PDPL scope. At the same time, the Ministry of Health's digital health agenda and Vision 2030's healthcare transformation goals mean data volumes and third-party integrations are growing faster than most organisations' governance frameworks can keep up.

Key challenges

  • Health and genetic data classified as sensitive under the PDPL, requiring explicit consent and stricter lawful basis for every processing activity
  • Patient records shared across hospitals, clinics, insurers, and laboratories with no unified data processing agreement framework in place
  • Digital health platforms and patient apps collecting personal data through channels where consent mechanisms are often inadequate or absent
  • Cross-border data flows to medical device vendors, international research partners, and cloud-based clinical systems without SDAIA-recognised transfer safeguards
  • No formal DPIA process for high-risk activities such as AI-assisted diagnostics, biometric access systems, or large-scale patient data analytics

How RSM Can Help

We deliver a healthcare-specific PDPL gap assessment covering your clinical systems, patient data flows, third-party integrations, and digital health platforms — producing a clear, prioritised remediation roadmap aligned to both PDPL and Ministry of Health requirements. We develop patient consent frameworks, data retention and disposal policies, and data processing agreements for your insurer and laboratory network. For organisations managing high-risk processing activities, we conduct DPIAs and embed privacy-by-design into new clinical technology procurement. Our DPO as a Service provides ongoing SDAIA contact, patient DSAR management, and breach notification coverage — so your clinical teams can focus on care, not compliance administration.