thomasmoreai/arckit-uae-pdpl

> ⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output should be reviewed by qualified DPO / RSSI / federal compliance counsel before reliance. Citations to UAE Cabinet / PDPL / IAS / Cybersecurity Council text may lag the current text — verify against the source.

User Request

text
$ARGUMENTS

You are an enterprise architect generating a UAE PDPL Compliance Assessment for a federal entity.

Process

1. Read prerequisites:

• projects/000-global/ARC-000-PRIN-*.md (federal principles, if present)
• The project's REQ, DR, and DMOD artefacts (if present)
• .arckit/templates/_partials/RENDERING.md

1. Read the template:

• First, check .arckit/templates-custom/uae-pdpl-template.md (user override)
• Then, .arckit/templates-custom/uae-pdpl-template.md
• Fallback, .arckit/templates/uae-pdpl-template.md

1. Use scripts/bash/generate-document-id.sh PDPL --filename for the artefact filename.
2. Resolve the <!-- DOC-CONTROL-HEADER --> marker per RENDERING.md.
3. Generate the following sections:

• Scope — what processing is covered, what carve-outs apply. Note free-zone regimes DIFC DPL and ADGM DPR are out of scope of the federal PDPL; healthcare data may also fall under ADHICS.
• Lawful basis register — per processing activity, citing PDPL Article 5 (lawful processing) and Article 6 (consent).
• Data subject rights procedure — access, rectification, erasure, restriction, portability, object, withdraw consent, complain to the Data Office. State the channel, the response SLA, and the operational owner for each right.
• DPIA — assess each PDPL Article 21 trigger (new technology, large-scale processing, profiling/automated decisions, systematic monitoring, sensitive categories under Article 7). For each triggered category, document the impact assessment, the residual risk, and the operational mitigations.
• Cross-border transfer log — assess each transfer against PDPL Article 22 (adequate countries) and Article 23 (derogations / SCC-equivalent). Note transfers to countries without a UAE adequacy designation require a written agreement and an explicit derogation.
• Breach notification playbook — PDPL Article 9 obligations to the Data Office and to affected data subjects, with applicable timelines and the operational owner.
• Penalties (informational only) — reference current administrative fines per the relevant Cabinet Resolution. This section is informational and is not used for compliance scoring.

1. Populate the External References section per .arckit/references/citation-instructions.md. Federal Decree-Law No. 45 of 2021 MUST appear in the Document Register with its primary URL and the verification date.
2. Write the artefact via the Write tool to projects/<project-id>/<filename>.
3. Show only a summary to the user (one paragraph plus the headline DPIA outcome and any cross-border transfers flagged).

Authoritative anchor

Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. Authority: UAE Data Office. Primary URL: <https://uaelegislation.gov.ae/en/legislations/1972/download>

The PDPL Executive Regulation status MUST be flagged as "verified as of date]" in the External References section because publication status changes — see docs/guides/uae-overlay-maintenance.md for the current verification date.

Important notes

• Do NOT confuse the federal PDPL with the DIFC DPL or ADGM DPR free-zone regimes — those are separately maintained and out of scope of this command.
• Healthcare data in some emirates additionally falls under ADHICS — flag as a follow-up where relevant.
• Where the Executive Regulation is not yet in force at the verification date, treat its provisions as informational only and base the assessment on the primary Decree-Law text.

Suggested Next Steps

After completing this command, consider running:

• $arckit-risk -- DPIA outputs feed the risk register's privacy and regulatory entries.
• $arckit-uae-data-sharing -- Per-share lawful-basis mapping continues into the data sharing agreement.
• $arckit-uae-classification -- PDPL-relevant datasets must be classified appropriately.