On February 14, 2021, the Abu Dhabi Global Market (“ADGM”), one of two significant financial services free zones in the United Arab Emirates, enacted its new Data Protection Regulations 2021 (the “Regulations”).  The Regulations will come into force and replace the current Data Protection Regulations 2015 following a transition period of 12 months for current establishments (i.e., those established in ADGM prior to February 14, 2021) and 6 months for new establishments (i.e., those established in ADGM on or following February 14, 2021).

Similar to recently introduced data protection laws in other jurisdictions, such as Brazil and the Dubai International Financial Centre, the Regulations are modeled after the European Union’s General Data Protection Regulation, which ADGM deemed to be “the leading international standard and best practice for robust Data Protection legislation” following its international benchmark of standards and best practices.

The Regulations also introduce an independent Office of Data Protection serving functions similar to the European Data Protection Board.  The Office will be headed by a Commissioner of Data Protection appointed by ADGM, and its responsibilities will include promoting data protection within ADGM, maintaining a register of data controllers, enforcing obligations upon data controllers, and upholding the rights of individuals.

We will continue to monitor the implementation of the Regulations.  Feel free to reach out to a member of our team if you have any questions.