Health and family notes need permission (Art. 16)
Data leaving the QFC needs a basis (Arts. 23, 24)
Personal and financial data processed in Qatar only (cl. 21.4)
Tokens are still personal data, and whoever holds the mapping can reverse them. An outside path still needs its own basis under your rulebook. An air-gapped setup has no outside path.
| Rule | Requirement | Protecto solution |
|---|---|---|
| Which rulebook appliesLaw 13, Art. 2 QFC Regs, Arts. 2, 7 QCB Cloud Reg, cl. 5.1 | Law No. 13 covers electronic processing of personal data. The QFC Regulations cover firms registered in the QFC, and others that process through them on an ongoing basis. The QCB regulation covers cloud use by QCB-licensed entities. One group can face all three. | Protecto applies a policy per use case, so each unit gets the rule that fits it. The checkpoint is the same. |
| Where data is processedQCB Cloud Reg cl. 21.4, 21.5 Law 13, Art. 15 | A QCB entity must ensure personal and financial information is processed within Qatar only, and get QCB approval before a cloud arrangement. Law 13 has no hosting rule. | Protecto runs on-premises, in your private cloud, or air-gapped, with the model inside the same boundary. Real values, mappings, and keys stay in your environment. |
| Transfers out of the QFCQFC Regs Arts. 23, 24 | A recipient outside the QFC needs an adequate jurisdiction, safeguards such as standard clauses, a listed derogation, or a permit. | Protecto sends tokens, not real values. Tokens are still personal data, so the basis for the path stays your decision. |
| Special-nature and sensitive dataLaw 13, Arts. 16, 24 QFC Regs, Art. 12 | Law 13: health, children, marital relations, ethnic origin, religious creeds, and criminal offenses need the Competent Department's permission. QFC: sensitive data is barred unless a listed ground applies. | Protecto flags these notes in Arabic and English text and holds them back from the model, the index, and the logs unless your policy releases them. Test it on your own tickets. |
| Security and pseudonymizationLaw 13, Arts. 8(3), 13 QFC Regs, Arts. 26, 29 | Precautions that fit the nature and importance of the data. The QFC Regulations name de-identification or encryption, and access only for roles that need the data. | Tokens replace real values before data reaches a model, and map back only under policy. The QFC Data Protection Office says de-identified data is still personal data. |
| Processors, records, and breachesLaw 13, Arts. 11(8), 12, 14 QFC Regs, Arts. 28, 30, 31 | Verify processors, keep records, and report breaches. QFC: to the Data Protection Office within 72 hours where feasible. Law 13: tell the person and the Competent Department if serious damage is possible. | Real values stay out of models, vector stores, and logs, so less is exposed. The audit log shows what each recipient received. |
| Review before launchLaw 13, Art. 11(1) QFC Regs, Art. 27 | Review privacy measures before new processing. The QFC requires an impact assessment for high-risk processing, including large-scale sensitive data. | The scan shows which sensitive data a flow touches, so your review starts from facts. |
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