PDPL Data Mapping Gaps in Saudi Arabia: What Businesses Need to Identify
By Rahman Iqbal 24-08-2026 1
As businesses in Saudi Arabia collect personal information through websites, mobile applications, HR platforms, customer systems, cloud services, and third-party providers, understanding where personal data exists has become increasingly important. PDPL Gap Assessment Saudi Arabia can help organizations identify weaknesses in their current privacy practices, but effective preparation starts with understanding how personal data moves throughout the business. This is where data mapping becomes a critical part of privacy management.
A data map provides a structured view of what personal data an organization collects, why it is processed, where it is stored, who can access it, which third parties receive it, and what happens to it when it is no longer needed.
What Is Personal Data Mapping?
Personal data mapping is the process of identifying and documenting the flow of personal information throughout an organization.
A typical data map may capture:
- What personal data is collected
- Where the data comes from
- Why the organization processes it
- Which departments use it
- Where it is stored
- Who has access to it
- Which systems process it
- Which third parties receive it
- Whether it moves between locations or systems
- How long it is retained
- How it is eventually deleted or disposed of
The objective is to create visibility into the personal data lifecycle.
Without this visibility, businesses may struggle to determine whether their privacy controls are actually covering all relevant processing activities.
Why Data Mapping Matters for PDPL Compliance
Data mapping provides the foundation for many privacy management activities.
When an organization understands its personal data flows, it becomes easier to evaluate areas such as privacy notices, consent practices, access controls, retention, third-party processing, data subject requests, security safeguards, and incident response.
Without an accurate data map, organizations may overlook personal information stored in less obvious locations.
For example, a company may know that customer information exists in its CRM system but overlook copies stored in:
- Marketing platforms
- Customer support tools
- Email systems
- Shared drives
- Analytics platforms
- Cloud storage
- Mobile applications
- Backup systems
- Third-party platforms
These overlooked locations can create data governance and privacy gaps.
1. Identify Every Personal Data Source
The first major data mapping gap is incomplete discovery.
Businesses often start with their primary databases and applications but fail to consider all the places where personal information enters the organization.
Potential sources include:
- Website forms
- Mobile applications
- Customer portals
- Call centers
- Physical forms
- HR systems
- Recruitment platforms
- Marketing campaigns
- Online transactions
- Customer service interactions
- Vendor systems
Organizations should create an inventory of these sources before attempting to map data flows.
2. Identify What Types of Personal Data Are Collected
Knowing that a system contains “customer information” is not enough.
Organizations should identify the categories of personal data being processed.
Depending on the business, this may include:
- Names
- Contact information
- Identification details
- Account information
- Employment information
- Transaction information
- Device information
- Location information
- Communication records
- Customer preferences
Businesses should also pay particular attention to information that may require additional consideration because of its sensitivity or potential impact on individuals.
The more precisely data categories are documented, the easier it becomes to determine appropriate privacy and security controls.
3. Document the Purpose of Processing
A major data mapping gap occurs when organizations cannot clearly explain why personal information is being collected or processed.
For each processing activity, businesses should document its business purpose.
For example, personal information might be processed for:
- Delivering products or services
- Managing customer accounts
- Employee administration
- Recruitment
- Customer support
- Billing
- Marketing
- Fraud prevention
- Service improvement
The purpose should be specific enough to explain why the organization needs the information.
4. Identify the Systems That Process Personal Data
Personal data frequently moves between multiple applications.
For example, customer information may begin on a website, move into a CRM platform, be sent to a customer service system, and then be shared with an external service provider.
A complete data map should identify the systems involved in these flows.
Consider documenting:
- Application name
- System owner
- Data processed
- Business purpose
- Integration points
- Users with access
- Storage location
- Third-party connections
This provides a clearer picture of the organization's overall processing environment.
5. Map Internal Data Movement
Personal information does not remain within a single department.
Customer data may move between sales, marketing, finance, customer service, operations, and IT.
Employee information may move between HR, payroll, management, benefits providers, and other internal functions.
Organizations should therefore document internal data flows and identify why information moves between departments.
This can help uncover unnecessary duplication, excessive access, and unclear ownership.
6. Identify Third-Party Data Sharing
Third-party processing is one of the areas organizations should examine carefully.
Businesses may use external providers for:
- Cloud hosting
- Payroll
- Marketing
- Customer support
- Analytics
- Payment processing
- Recruitment
- IT services
- Document management
- Communication platforms
For each third party, organizations should understand what personal data is shared, why it is shared, what services are provided, and what contractual and security controls apply.
An incomplete vendor inventory can create significant blind spots in a data mapping exercise.
7. Identify Cross-Border Data Flows
Organizations using international cloud platforms, global applications, or overseas service providers should understand where personal information may be transferred or made accessible.
A data map should identify relevant transfer points and the systems involved.
Businesses should consider:
- Which data is transferred
- Why the transfer occurs
- Which provider receives the information
- Where the information is processed
- What safeguards are applied
- What contractual arrangements exist
Cross-border data flows should not be assumed simply because a vendor is headquartered in another country. Organizations should understand the actual data-processing architecture and access arrangements.
8. Review Data Retention and Deletion
Another common gap is the inability to explain what happens to personal data after its business purpose has ended.
A strong data map should connect processing activities with retention requirements.
Organizations should identify:
- How long information is retained
- Why it is retained
- Which system stores it
- Who controls retention
- Whether backups contain copies
- How information is deleted
- Whether third parties also remove the information
This can help organizations identify unnecessary data accumulation.
Keeping personal information indefinitely can increase the potential impact of a security incident and make data management more difficult.
9. Include Shadow Data and Unstructured Information
Data mapping often focuses heavily on structured systems.
However, personal information may also exist in:
- Email inboxes
- Spreadsheets
- Shared folders
- Collaboration tools
- Presentation files
- PDF documents
- Local computers
- Messaging platforms
These areas can be difficult to discover and manage.
Organizations should consider whether employees are creating unofficial copies of personal information and whether those copies are subject to appropriate access and retention controls.
10. Connect Data Mapping With Access Management
Once personal data locations are identified, organizations should examine who can access that information.
For each important data repository, consider:
- Which employees have access?
- Is access role-based?
- Are privileged accounts monitored?
- Are inactive accounts removed?
- Are access rights periodically reviewed?
- Do third parties have access?
- Is access greater than what employees actually need?
This allows data mapping to become more than a documentation exercise.
How to Identify Data Mapping Gaps
Businesses can conduct a structured review using the following process:
Step 1: Create a data inventory
List systems, applications, databases, repositories, and business processes involving personal data.
Step 2: Identify data categories
Document the types of personal information handled by each process.
Step 3: Map data flows
Record where information comes from, where it moves, and where it ends up.
Step 4: Identify recipients
Document internal departments and external organizations that receive or access personal data.
Step 5: Review processing purposes
Confirm that each processing activity has a clearly documented purpose.
Step 6: Review retention
Determine how long information remains in each system and what happens afterward.
Step 7: Identify gaps
Look for unknown systems, undocumented transfers, excessive access, unclear ownership, missing records, and unmanaged data copies.
Step 8: Prioritize remediation
Address the highest-risk gaps first and establish responsible owners and target completion dates.
Common Data Mapping Mistakes
Businesses should watch for several recurring problems:
- Mapping only major databases: Personal information may exist across dozens of less visible locations.
- Ignoring third parties: External processors can create significant gaps if their data flows are not documented.
- Failing to update maps: Data environments change whenever systems, vendors, applications, or business processes change.
- Not assigning ownership: A data map without responsible owners can quickly become outdated.
- Treating mapping as a one-time project: Data mapping should evolve with the organization's processing activities.
Final Thoughts
An accurate personal data map gives businesses a clearer understanding of how information moves throughout their organization. It helps reveal hidden data repositories, undocumented processing activities, unnecessary access, third-party exposure, retention issues, and potentially overlooked data flows.
For businesses operating in Saudi Arabia, data mapping should be treated as an ongoing privacy management activity rather than a document created solely for compliance purposes.
The strongest approach is to connect data mapping with privacy policies, processing records, access management, vendor management, retention practices, security controls, and incident response.
When organizations know what personal data they have, where it exists, why it is processed, who can access it, where it goes, and when it should be removed, they are in a much stronger position to identify privacy gaps and build a more effective personal data protection program.
