Data Processing Addendum Template for United Arab Emirates

The Data Processing Addendum (DPA) is a crucial legal document required whenever an organization (data controller) engages another party (data processor) to process personal data on its behalf within the UAE jurisdiction. This document has become increasingly important following the implementation of Federal Decree Law No. 45 of 2021, which established comprehensive data protection requirements in the UAE. The DPA supplements existing service agreements by detailing specific data protection obligations, security measures, and compliance requirements. It includes provisions for data breach notification, sub-processor engagement, cross-border transfers, and audit rights, ensuring alignment with UAE data protection laws and regulations. The document is essential for demonstrating compliance with UAE data protection requirements and establishing clear accountability in data processing relationships.

1. Parties: Identification of the data controller and data processor, including full legal names and registration details

2. Background: Context of the relationship between parties and reference to the main agreement this DPA supplements

3. Definitions: Key terms used in the DPA, aligned with UAE Federal Decree Law No. 45 of 2021 definitions

4. Scope and Purpose: Details of the data processing activities covered by the agreement

5. Roles and Responsibilities: Clear delineation of roles as controller and processor, and respective obligations

6. Processing Instructions: Controller's documented instructions for processing, including permitted purposes and restrictions

7. Data Protection Obligations: Processor's obligations regarding data security, confidentiality, and compliance with UAE data protection laws

8. Technical and Organizational Measures: Security measures required to protect personal data

9. Sub-processing: Conditions and requirements for engaging sub-processors

10. Data Subject Rights: Procedures for handling data subject requests and processor's assistance obligations

11. Data Breach Notification: Procedures and timeframes for reporting data breaches

12. Audit Rights: Controller's rights to audit processor's compliance

13. Cross-border Transfers: Requirements and safeguards for international data transfers

14. Term and Termination: Duration of the DPA and termination provisions

15. Return or Deletion of Data: Obligations regarding personal data upon termination

16. Governing Law and Jurisdiction: Confirmation of UAE law application and jurisdiction