What customer data reaches the vendor?
Can the vendor reuse it?
Who saw real values?
1087654321 → [ID_2f9]The same customer always gets the same token, so the model can still follow the file.
credit tool ← IBANA tool or role gets the real value its task needs, and the release is logged.
credit history → not sentCredit data the use case does not need stays away from the model (PDPL Art. 11(3)).
Public or hybrid cloud needs SAMA approval, and cloud outside the Kingdom needs explicit approval. Private cloud is out of scope.
With ProtectoProtecto runs where your data already is, so you can pick the model's home on its own merits: a model you host, an in-Kingdom cloud, or an approved provider.
The provider must not use your data for secondary purposes. That is a contract promise you have to trust.
With ProtectoThe provider receives tokens. Whatever happens to the data on its side, the real names, IDs and IBANs were never there.
Sharing customer data can make outsourcing material, and any overseas provider needs a written SAMA no objection.
With ProtectoYour request can list, field by field, what the provider receives. SAMA still makes the call; your file is precise.
Access follows need-to-know, with an audit trail. AI tools blur that, because one answer can draw on many records.
With ProtectoEvery unmask is a logged decision: which role or tool, which value, when. The log stays with you.
| Rule | Requirement | Protecto solution |
|---|---|---|
| Risk assessment for new technologySAMA CSF 3.2.1 PDPL IR Art. 25 | Run a cyber security risk assessment when launching new products and technologies and when outsourcing is considered. The PDPL adds a written impact assessment for processing based on newly adopted technologies. | Protecto gives the assessment one data path to describe: what each model, store and tool receives, field by field, for every AI use case. |
| Cloud servicesSAMA CSF 3.4.3 | SAMA approval before using hybrid or public cloud. In principle, cloud located in Saudi Arabia; abroad needs explicit approval. The provider must not use your data for secondary purposes. Private cloud is out of scope. | Protecto runs on your servers or private cloud. A cloud model receives tokens, so the provider never holds the real customer values it could reuse. |
| OutsourcingSAMA Rules on Outsourcing Rules 10, 23, 42 | Material outsourcing, which can include sharing customer data, needs a written SAMA no objection at least 15 business days ahead (30 for foreign banks). Overseas providers need a no objection, a reason the work cannot be done in the Kingdom and legal opinions. | Your request can state exactly which fields a provider receives: tokens, with the mapping kept apart from the provider. SAMA still decides whether the arrangement is material. |
| Customer confidentialitySAMA Rules on Outsourcing Rules 24, 25 | Before customer data goes to a third party, meet the customer-confidentiality rules, including Article 19 of the Banking Control Law, and keep safeguards for its integrity and confidentiality. | Customer names, IDs, account numbers and IBANs become consistent tokens before they leave for any vendor. |
| Need-to-know accessSAMA CSF 3.3.5 CSF 3.3.6 | Restrict access on need-to-have and need-to-know, keep an audit trail of access, and protect customer data in applications to avoid unauthorized access and data leakage. | Real values return only to the roles and tools your policy names. Every unmask is logged, so you can show who saw which value. |
| Credit dataPDPL Art. 24 PDPL IR Arts. 11, 27 | Extra controls for credit data, explicit consent, and the requirements and controls issued by the Saudi Central Bank. | Policy keeps credit fields a use case does not need away from the model, and masks the rest. |
| Purpose and minimum dataPDPL Art. 11(3) SAMA Data Privacy circular | Collect and use only the data the purpose needs. SAMA asks institutions to review policies against the PDPL, report gaps to the Board, and use customer data only for the purpose it was collected for. | Each AI flow gets only the fields its task needs, and the audit log shows where each value went. |
Every institution SAMA regulates: banks, insurance and reinsurance companies, financing companies and credit bureaus operating in Saudi Arabia, plus the Financial Market Infrastructure (CSF 1.4). The framework is mandatory, and it replaced SAMA's earlier cyber security circulars.
Not if the model runs on private cloud. CSF 3.4.3 covers hybrid and public cloud and says it does not apply to private cloud services (internal cloud). A model you host on your own servers or private cloud, with Protecto next to it, stays out of that rule.
CSF 3.4.3 says that, in principle, only cloud services located in Saudi Arabia should be used, and cloud services abroad need explicit SAMA approval. The PDPL adds its own conditions for transfers outside the Kingdom (Article 29). Protecto reduces what such a model receives to tokens, but the path still needs those approvals.
It can be. SAMA's Rules on Outsourcing define outsourcing as another party performing, on a continuing basis, a function the bank could do itself, and they list sharing customer data as a factor that makes outsourcing material. Material outsourcing needs a written SAMA no objection, and so does any outsourcing to a provider overseas. Whether a given AI service counts is a call for SAMA and your counsel.
Treat it as customer data. Tokenization is pseudonymization: whoever holds the token mapping can reverse a token. Under Article 9 of the PDPL Implementing Regulation, data stops being personal data only if re-identification is impossible. Protecto keeps the mappings apart from the model provider, so the provider never holds the real values.
No. The CSF lists data-leakage prevention among your infrastructure controls, and your DLP keeps doing that job on email, endpoints and the network. Protecto covers the AI data path, where data moves into models, vector stores, agent memory and tool calls, and where blanking the text would break the answers.
On your servers, in your private cloud, air-gapped with a model you host, or as Protecto's SaaS. For SAMA-regulated data most teams start on-premises or in private cloud. SaaS is itself a cloud service and goes through the same CSF 3.4.3 review as any other provider.
Yes. Detection is tested in seven languages, including Arabic and English, and works on mixed Arabic and English text. Protecto detects 50+ entity types out of the box, and you can add custom entities for identifiers specific to your institution. Test it on a sample of your own records.
A path-by-path map of what may leave the Kingdom, and on what footing.
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