Analyzing critical legal trends and developments across data, cyber, AI and digital regulations from around the world and beyond borders

Qatar’s Personal Data Privacy Protection Law (“PDPPL“) was the first national data protection law in the Arabian Gulf region when it was issued in 2016. While the regulatory authority has historically focused on awareness-raising in relation to the new rules – including the issuance of various supplementary guidelines for regulated entities and individuals – a number of recent decisions have shown that the regulator is now prepared to enforce against organisations that fail to comply with the law.


Case summaries

The following binding decisions have been publicised by the regulator:

  • ICT provider censured following data subject complaints

December 2024: The National Data Privacy Office (“NDPO”), part of the National Cyber Security Agency (“NCSA”), issued a ruling requiring a company in the ICT sector to strengthen its compliance with the PDPPL by enhancing and monitoring its administrative, technical, and financial measures to safeguard personal data effectively.

The NDPO website reported that this matter was prompted by an investigation into the company’s processing of personal data following a formal complaint filed by an individual in 2023. The complainant alleged that the organisation had used their personal data without consent. After investigation, the NDPO found the company in violation of several provisions under the PDPPL, including the obligation not to process personal data without consent or a lawful purpose,  the requirement to implement appropriate safeguards, the principle of data accuracy, and the obligation to oversee compliance of third party processors.

The NDPO issued a binding decision requiring the controller to take immediate action to address the identified issues. The company’s cooperation during the investigation and its commitment to improving its data protection practices were noted in the decision, and helped the company to avoid public censure by the NDPO.

  • E-commerce company sanctioned following data breach

March 2025:An e-commerce company was ordered to enhance its compliance with the PDPL and to strengthen and monitor its administrative, technical, and financial procedures to ensure the effective protection of personal data following an NDPO investigation that resulted from an initial data breach incident.

The NDPO found that the controller had violated a number of provisions in the PDPL relating to obtaining individual consent, implementing appropriate safeguards for personal data, ensuring data accuracy, and supervising compliance with respect to the processing of personal data.

  • Contracting company required to address privacy controls

April 2025: A local contracting company in Qatar was the subject of a decision requiring it to enhance data protection controls after being found to have violated numerous provisions of the PDPL.

The NDPO issued a binding decision required the company to strengthen, develop, and monitor its administrative and technical procedures and take the necessary precautions to ensure the protection of the privacy of personal data. The company was given a 60-day period from the date of the decision to comply with the order.

Key takeaways

These decisions mark an important step in the evolution of Qatar’s data protection regime by demonstrating the increased desire of the regulatory authority to monitor, investigate and sanction controllers for non-compliance with the PDPPL.

All organisations operating in Qatar should ensure that personal data is processed in accordance with the legislation or face the prospect of sanctions from the NDPO.

Author

Dino Wilkinson leads Baker McKenzie’s IP, technology and data practice in the Middle East. He is recognised as one of the leading technology lawyers in the region with top-tier team and individual rankings in Chambers Global Guide and the Legal 500.