Egypt’s PDPL Execution Plan with TurtleShield: Six Steps to your Compliance Journey

Sameer Ahirrao -

Egypt's Personal Data Protection Law (PDPL), Law No. 151 of 2020, is a landmark regulation that marks a transformative shift in how organizations must collect, process, and manage personal data. As enforcement ramps up, it's crucial for businesses to proactively implement structured compliance mechanisms across the data lifecycle.

This blog outlines a practical execution plan aligned with key PDPL requirements, focusing on risk assessments, data discovery, subject rights, consent management, storage limitation, and breach response, to ensure full regulatory alignment.

1. Conduct PIA/DPIA/TIA (Risk Assessments)

PDPL Articles: 9, 14, 15

To ensure lawful processing and cross-border transfers, organizations must conduct:

  • Privacy Impact Assessments (PIA) and Data Protection Impact Assessments (DPIA) to evaluate the risks associated with processing PII (Personally Identifiable Information).
  • Transfer Impact Assessments (TIA) to assess the adequacy of protection for personal data transferred outside Egypt.

Ardent Solution: The TurtleShield PA (Privacy Automation) automates and streamlines privacy-related processes and tasks. Conducting DPIAs and TIAs enhances privacy practices, ensures Egypt's PDPL compliance with applicable privacy laws, and also protects sensitive information.

2. Discover PII and Build a Data Bill of Materials

PDPL Articles: 4, 5, 9

Understanding what data your organization processes is foundational to compliance. This includes:

  • Performing data discovery and mapping to classify PII.
  • Creating a Data Bill of Materials (DBoM) and a Record of Processing Activities (RoPA).
  • Conducting regular audits to ensure up-to-date data inventory and compliance with PDPL obligations.

Ardent Solution: Our Innovative and patented technology "TurtleShield DD (Data Discovery)" addresses these challenges by discovering hard-to-find datasets at scale, enabling quick actions, and reducing compliance costs. It locates and categorizes data based on regulatory requirements in PDPL, ensuring companies maintain compliance, secure sensitive information, and minimize data breach risks.

3. Implement Data Subject Rights Management

PDPL Article: 2

The PDPL grants rights to individuals, including:

  • The Right to Receive Information
  • The Right to Request Transfer of Personal Data
  • The Right to Stop Processing
  • The Right to be notified with any infringement to Personal Data
  • The Right to withdraw the prior consent
  • The Right to to correct, edit, delete, add or update Personal Data

Organizations must:

  • Develop a secure Data Subject Access Request (DSAR) portal.
  • Integrate data discovery modules to enable privacy teams to respond efficiently to DSARs.

Ardent Solution: TurtleShield DSAR streamlines the Data Subject Access Request (DSAR) process, ensuring efficient compliance with PDPL. It offers a centralized portal for intake, automated data discovery, and secure response delivery.

4. Establish Centralized Consent Management System

PDPL Articles: 2, 4, 6, 12, 17

Consent lies at the heart of PDPL. Compliance demands:

  • A centralized system for collection, storage, and withdrawal of consent.
  • Real-time preference management for marketing and other processing purposes.
  • A clear and accessible privacy notice for all Data Subjects.

Ardent Solution: TurtleShield CM (Consent Management) automates required user privacy notices, the gathering and management of consent/opt-out privacy preferences, and the operational honoring of preferences by both internal and downstream third-party data sharers.

5. Enforce Storage Limitation Requirements

PDPL Article: 3

To align with PDPL's data minimization principles, organizations should:

  • Implement automated storage limitation rules to retain personal data only as long as necessary.
  • Erase or anonymize data that is no longer required for the original purpose.

Ardent Solution: TurtleShield DM (Data Minimization) helps you reduce the data and focus on enterprise-centric data. It can provide you detailed insights to get rid of non-essential data, reducing cost of security and storage and building confidence of business owners and data custodians.

6. Implement Data Disclosure and Breach Management

PDPL Articles: 7, 9

Timely response to data breaches is non-negotiable under PDPL. Organizations must:

  • Automate breach detection and response processes.
  • Notify the Center for Data Protection within 72 hours of discovery.
  • Alert affected Data Subjects within 3 days after notifying the Center.
  • Notify national security authorities immediately if the breach has national security implications.

Ardent Solution: TurtleShield DBM (Data Breach Management) module helps organizations efficiently verify, assess, contain, manage and respond to data breaches including notifying affected individuals and regulatory bodies as per the legal requirements. TurtleShield DBM streamlines data breach management process, handles stakeholder management, accelerates breach response, enabling organizations to notify regulators and stakeholders within the required timeframe.

Follow PDPL Timelines

1. Infringement Occurs – Day 0

2. Notify the Center

  • Within 72 hours by Controller/Processor
  • Immediate notification if national security is involved

3. Center Notifies National Security Authorities

  • Immediately upon awareness
  • Full details within 72 hours

4. Notify Data Subject

  • Within 3 days after notifying the Center
  • Include details of the breach and actions taken

5. Data Subject Request Response Deadline - Within 6 working days; No response within the period = deemed rejected

6. Decision on Disclosure Request - Within 6 working days; No response within the period = deemed rejected

Conclusion

Complying with Egypt’s Personal Data Protection Law (PDPL) requires more than policy updates, it demands operational readiness across systems, processes, and teams. From conducting risk assessments and mapping personal data to managing subject rights and breach notifications, every requirement has defined timelines and legal consequences.

Organizations should approach PDPL execution as a structured, ongoing process, ensuring each component from consent management to storage limitation, is well-documented, auditable, and integrated into daily operations.

By aligning with the PDPL now, organizations can avoid regulatory risk, reduce exposure from data incidents, and maintain accountability in how personal data is handled internally and externally.