With the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), which came into force on January 2, 2022, the UAE has created a comprehensive law on the protection of personal data for the first time. This law marks a fundamental paradigm shift: Data protection, which previously played only a subordinate role in the legislation of the UAE and the Gulf region, is now being aligned to a greater extent with international data protection standards, in particular the GDPR. Although the PDPL in its current wording already makes explicit reference to employees and the processing of their personal data in several places, there is still a lack of a sufficiently clear labor law basis within the UAE Labor Law that specifically regulates the data protection-compliant processing of employee data. In practice, this legal gap raises numerous questions of interpretation and delimitation, which pose legal uncertainties for both employers and employees. The article Employee Data Protection in the United Arab Emirates by Sebastian Luermann, published in issue 03/2025 of the journal Datenschutz-Berater, presents the main features of employee data protection in the United Arab Emirates (UAE) and analyzes the current legal situation in light of the new data protection law.
Data Protection Advisor
Issue 03/2025
With the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), the UAE has for the first time created a comprehensive law for the protection of personal data.

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