DIFC vs ADGM: How UAE Free Zone Privacy Laws Work (and What GDPR Teams Must Do)
This episode continues our UAE privacy series by moving from the federal PDPL to two major free zones: the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM). Built to attract global finance and technology firms, both zones have their own regulators and data protection laws. The result is a GDPR inspired framework that is more detailed than the federal baseline.
The conversation starts with the question every compliance team must answer first: Which law applies? If an organisation is established in DIFC or ADGM, the free zone regime generally governs processing in that zone, and the federal PDPL does not apply where a free zone has its own legislation. Complexity increases when operations span multiple jurisdictions, create an onshore nexus through staff or customers, or fall within sectors that add extra rules. The hosts advise mapping processing by establishment, location, and sector, then applying the strictest standard.
For GDPR mature organisations, much will feel familiar. Both regimes use the controller and processor model, recognise the six lawful bases including legitimate interests, and expect governance measures such as DPIAs, records of processing, and privacy by design and by default. The episode also warns against overconfidence. Regulators can apply similar concepts with different expectations, and rights handling is assessed as a real process. An ADGM enforcement example shows that poor data subject access request procedures can trigger penalties.
International transfers are covered through adequacy and safeguards, supported by contractual tools and binding corporate rules. Breach notification is clearer than the federal baseline, with ADGM requiring reporting within 72 hours where feasible, and DIFC adopting an ‘as soon as practicable’ standard. The closing message flags DIFC’s 2025 private right of action, raising the stakes for contracts, liability allocation, insurance, and incident readiness. It is a roadmap for practical delivery.
