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Privacy Law Crosswalk

Purpose: Let a team that runs AI systems across several jurisdictions see, theme by theme, where eight privacy laws ask for the same thing and where they differ, and which wiki controls answer each theme.

Audience: Privacy and data protection officers, legal and compliance teams, GRC teams, AI product owners.

How to use: Find the theme in the first column, read across to the laws that apply to you, then open the wiki controls in the last column. Each law's ID (for example E2 or U1) is its row in the regional crosswalk, which records the instrument's legal force and verification status.

Verification required. Every provision number on this page is [Recalled]: stated from memory of the law and not checked against the primary text. Cells marked [Unverified] are less certain still. "Not researched" means this wiki has no information, which is different from the law being silent. Implementing regulations and regulator guidance change the detail in every one of these laws. Check the primary text before relying on any cell. This is not legal advice.

The eight laws

Law Jurisdiction Regional row Regional section
General Data Protection Regulation (GDPR), Regulation (EU) 2016/679 European Union E2 EU Regulatory Crosswalk
California Consumer Privacy Act (CCPA), as amended, with its regulations California, US US8 US Regulatory Crosswalk
Quebec Law 25, which amended the Act respecting the protection of personal information in the private sector Quebec, Canada CA3 Canada Regulatory Crosswalk
Personal Data Protection Act 2012 (PDPA) Singapore SG4 Singapore Regulatory Crosswalk
Federal Decree-Law 45/2021 (UAE PDPL) United Arab Emirates, outside the DIFC and ADGM U1 GCC Regulatory Crosswalk
Personal Data Protection Law (Saudi PDPL) Saudi Arabia S1 GCC Regulatory Crosswalk
Law 13/2016 on personal data privacy protection (Qatar PDPPL) Qatar, outside the Qatar Financial Centre Q1 GCC Regulatory Crosswalk
Law 30/2018 (Bahrain PDPL) Bahrain B1 GCC Regulatory Crosswalk

The DIFC and ADGM free zones in the UAE have their own data protection laws (rows U6 and U7). DIFC Regulation 10 sets duties for autonomous and semi-autonomous systems that the federal law does not. They are not compared here.

European Union, California, Quebec and Singapore

Theme GDPR CCPA Quebec Law 25 Singapore PDPA Wiki controls
Automated decisions about individuals Art. 22: a right not to be subject to a solely automated decision with legal or similarly significant effect, with exceptions and safeguards Regulations on automated decision-making technology: pre-use notice, opt-out and access for significant decisions; see row US8 for dates s. 12.1: tell the person when a decision is made only by automated processing, explain it on request, and let them have it reviewed by a person No specific right. The PDPC advisory guidelines on AI recommendation and decision systems apply the general obligations AI-CTRL-013, AI-CTRL-023, AI-CTRL-041, AI-CTRL-045
Impact assessment before risky processing Art. 35: data protection impact assessment for high-risk processing Risk assessment regulations; see row US8 for dates s. 3.3: privacy impact assessment for any project that acquires, develops or redesigns a system that handles personal information No general duty. An assessment is required to rely on deemed consent by notification or on the legitimate interests exception AI-CTRL-042
Breach notification Arts. 33 and 34: to the authority within 72 hours, and to individuals when the risk is high Not in the CCPA itself. California's breach notice statute (Civil Code s. 1798.82) applies, and s. 1798.150 gives a private right of action after some breaches ss. 3.5 to 3.8: report a confidentiality incident that presents a risk of serious injury, and keep a register of all incidents Part 6A: notify the PDPC within 3 calendar days of assessing a breach as notifiable AI-CTRL-035, AI-CTRL-043
Transfers outside the jurisdiction Chapter V (Arts. 44 to 49): adequacy decision, safeguards or a derogation No restriction on transfers abroad s. 17: privacy impact assessment before personal information leaves Quebec s. 26: the recipient must give comparable protection AI-CTRL-007
Retention and deletion Art. 5(1)(e) storage limitation; Art. 17 erasure Disclose retention periods and keep data no longer than reasonably necessary; right to delete s. 23: destroy or anonymize when the purpose is met s. 25: stop retaining when the purpose no longer needs it. There is no right to erasure AI-CTRL-007, AI-CTRL-017
Requests from individuals Arts. 15 to 21: access, rectification, erasure, restriction, portability and objection Rights to know, delete, correct, and opt out of sale or sharing ss. 27 to 28.1: access, rectification, and an end to dissemination ss. 21 and 22: access and correction AI-CTRL-013
Vendors that process the data Art. 28: processor contract with set terms Written contract with each service provider and contractor s. 18.3: written agreement with the service provider Data intermediaries carry the protection, retention and breach duties directly; the organization stays responsible AI-CTRL-014

United Arab Emirates, Saudi Arabia, Qatar and Bahrain

Theme UAE PDPL Saudi PDPL Qatar PDPPL Bahrain PDPL Wiki controls
Automated decisions about individuals Art. 18: a right to object to decisions made by automated processing that have legal or serious effects Not researched Not researched Art. 22: a right to object to decisions based only on automated processing [Unverified] AI-CTRL-013, AI-CTRL-023, AI-CTRL-041, AI-CTRL-045
Impact assessment before risky processing Art. 21: data protection impact assessment for high-risk processing Required by the Implementing Regulation in listed cases [Unverified] Expected by the regulator's guidelines [Unverified] No impact assessment recalled. Some processing needs prior notice to, or authorization from, the Authority [Unverified] AI-CTRL-042
Breach notification Art. 9: to the Data Office, and to individuals where their privacy is at risk. The period is left to the Executive Regulation Art. 20, with 72 hours to the authority under the Implementing Regulation Art. 14: to the authority and the individual when serious damage may follow [Unverified] Not researched AI-CTRL-035, AI-CTRL-043
Transfers outside the jurisdiction Arts. 22 and 23: adequate protection, or a listed exception Art. 29 and the transfer regulation Art. 15 [Unverified] Arts. 12 and 13: adequate countries listed by the Authority, or its authorization [Unverified] AI-CTRL-007
Retention and deletion Art. 5: keep no longer than the purpose needs; Art. 15 erasure Art. 18: destroy when the purpose ends Not researched Not researched AI-CTRL-007, AI-CTRL-017
Requests from individuals Arts. 13 to 18 Art. 4 Not researched Not researched AI-CTRL-013
Vendors that process the data Art. 8: processor duties Art. 8: the controller must choose a processor that gives guarantees and stays responsible Not researched Not researched AI-CTRL-014

The GCC hub records open questions for these laws: the UAE Executive Regulation is reported as pending, and sources conflict on Saudi enforcement dates. See the GCC AI Regulatory Hub.

What the comparison shows

A programme built to the strictest cell in each row covers most of the others. For AI systems that usually means:

  • For automated decisions, tell the person, be able to explain the decision, and offer review by a person. Quebec asks for all three, and the GDPR and California regulations get there by other routes. CA-T2 is a record for one decision system.
  • Do an impact assessment before deployment for any AI system that handles personal data and affects people. EU T02 combines the data protection assessment with the AI Act's fundamental rights assessment.
  • Plan breach notification for 72 hours. Singapore's 3 calendar days run from the assessment of the breach, so the clock can start later than the GDPR's. The EU and GCC workflows set out the steps.
  • Record where prompts, logs and training data go for every AI vendor. California has no transfer rule, and the other seven laws each have one. The EU T04 and GCC T04 templates hold the record.

Deletion is where the laws differ most for AI. A right to erasure under the GDPR or the CCPA raises the question of personal data already used to train a model. Singapore has no erasure right at all.

What this page does not cover

  • Other privacy laws that the regional sections list, among them the UK GDPR, Brazil's LGPD, India's DPDP Act, China's PIPL, Japan's APPI and Australia's Privacy Act. Each has a row in its own regional crosswalk.
  • Sector privacy rules such as HIPAA. See the Sector Overlays.
  • Lawful basis for training a model on personal data, which turns on facts and regulator guidance more than on the text of the law.