Tokens are still personal data. A path outside the UAE still needs a basis under Articles 22 and 23, and health data still needs the Article 13 resolution. An air-gapped setup has no outside path.
| Rule | Requirement | Protecto solution |
|---|---|---|
| Health data stays in the StateHealth Law 2/2019 Arts. 13, 24 | Health data tied to services provided inside the State may not be stored, processed, generated, or transformed outside it, unless the Health Authority issues a resolution in coordination with the Ministry. | Protecto runs in the UAE, with real values, token mappings, and keys in your own environment. In an air-gapped setup the model runs inside the same boundary, so no health data goes outside. |
| Transfers outside the StatePDPL Arts. 1, 22, 23 | Transfer, sharing, or processing outside the State is allowed to destinations the Bureau approves (Art. 22), or in listed cases such as a contract, the person's explicit consent, legal claims, or the public interest. The Executive Regulations set the controls (Art. 23(2)). | Real values stay in the UAE. If you send tokens to a model abroad, that path is still personal data and needs its own Art. 22 or 23 basis. |
| Sensitive data and impact checksPDPL Arts. 1, 10, 21 | Health, biometric, family, religion, ethnic origin, and criminal-record data are sensitive. Large-scale sensitive processing needs an impact assessment and a Data Protection Officer. | Protecto detects 50+ entity types in Arabic and English, so you can show what a model sees. |
| Security and pseudonymizationPDPL Arts. 5(6), 7(1) and 7(2), 20 | Technical and organizational measures suited to the risk, including encryption and pseudonymisation. | Tokens replace real values before data reaches a model, and they map back only under policy. Keys and mappings stay in your environment. |
| Processors and recordsPDPL Arts. 7(4), 8 | Processors follow written instructions and must not disclose personal data except as the law allows. Controller and processor keep records that include cross-border movement. | The audit log shows what each recipient received, and it stays on your servers. |
| Breach noticePDPL Art. 9 | Notify the Bureau, and affected people where their privacy is at risk, within the period the Executive Regulations set. | Real values stay out of models, vector stores, and logs, so there is less to expose. The audit log shows who saw what. |
Identify the applicable privacy regime and protect data across AI workflows.
By submitting you agree to Protecto’s privacy policy.