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Free-zone (DIFC/ADGM) lawful-basis and special-category rules are well-documented and GDPR-aligned; federal PDPL detail on lawful bases beyond consent-plus-exceptions was not confirmed in available sources.
Sub-modules (4)
Lawful BasesAmber
PDPL defaults to consent with exceptions for public interest, judicial/security proceedings and public health; ADGM/DIFC mirror GDPR-style bases (consent, contract, legal obligation, public interest), though ADGM omits journalistic/artistic grounds.
Claims (2):
- Where consent is not an option or not practical, the PDPL permits processing only for protection of the public interest, judicial or security proceedings, protection of public health, or compliance with other laws such as KYC requirements.
- ADGM Data Protection Regulations provide lawful grounds for processing similar to GDPR — consent, contractual performance, controller obligations and public interest — but do not reference journalistic or artistic purposes as a legal basis.
Consent ThresholdsAmber
Consent is the PDPL's default processing basis; organizations must create consent forms/disclosures, falling back to enumerated statutory exceptions where consent is impractical.
Claims (1):
- Where consent is not an option or not practical, the PDPL permits processing only for protection of the public interest, judicial or security proceedings, protection of public health, or compliance with other laws such as KYC requirements.
Special CategoriesGreen
ADGM defines special categories consistently with GDPR while explicitly adding criminal data as a distinct category.
Claims (1):
- ADGM Regulations remain consistent with GDPR definitions of special categories of data while explicitly extending the category to include criminal data.
Pseudonymisation And AnonymisationAmber
ADGM references pseudonymisation (GDPR-consistent) as a security measure but does not explicitly define anonymisation; DIFC Law 2020 explicitly references both concepts without GDPR-level definitional specificity.
Claims (2):
- ADGM Regulations do not explicitly define anonymisation, although pseudonymisation is defined consistently with GDPR and referenced as an appropriate security measure.
- DIFC Law 2020 makes explicit reference to both anonymisation and pseudonymisation but does not define these concepts with GDPR-level specificity.
Sources and claims (5)
- ProbableIAPP — Where consent is not an option or not practical, the PDPL permits processing only for protection of the public interest, judicial or security proceedings, protection of public health, or compliance with other laws such as KYC requirements.observed
- ProbableOneTrust DataGuidance — ADGM Data Protection Regulations provide lawful grounds for processing similar to GDPR — consent, contractual performance, controller obligations and public interest — but do not reference journalistic or artistic purposes as a legal basis.observed
- ProbableOneTrust DataGuidance — ADGM Regulations remain consistent with GDPR definitions of special categories of data while explicitly extending the category to include criminal data.observed
- ProbableOneTrust DataGuidance — ADGM Regulations do not explicitly define anonymisation, although pseudonymisation is defined consistently with GDPR and referenced as an appropriate security measure.observed
- ProbableOneTrust DataGuidance — DIFC Law 2020 makes explicit reference to both anonymisation and pseudonymisation but does not define these concepts with GDPR-level specificity.observed