When you need this service
The board asks which rules apply
Your board, audit committee or a regulator asks which AI requirements apply to you and what evidence you hold, and nobody has a single answer.
AI in use but never listed
Staff tools, AI features in licensed software and assistants built by your own teams are all in use, without a register, owners or rules.
A new AI project or purchase needs approval
You need a consistent way to classify risk and check the vendor before approval. Deciding which use cases are worth building is AI Strategy & Readiness Assessment; this service sets the rules they are built and bought under.
An audit or ISO/IEC 42001 is ahead
An internal audit, a regulator's review or a decision to work towards ISO/IEC 42001 needs policies, records and evidence in order first.
The challenge
AI is spreading faster than policy. Staff try public tools, vendors switch on AI features in software you already license, and teams connect their own assistants to your data. As a result, it is often unclear which AI is in use, who owns each system and what data it reaches. So when the board asks which rules apply and whether you can show evidence, there is rarely a complete answer.
The rules that may apply to you do not carry the same force. The Personal Data Protection Law (PDPL) and its Implementing Regulations are law wherever personal data is processed, including in prompts, documents and outputs, and they require an impact assessment in cases such as processing sensitive data, using new technologies or making automated decisions. Sending personal data to a model that runs outside the Kingdom is a transfer question under the Regulation on Personal Data Transfer outside the Kingdom. The National Cybersecurity Authority (NCA) Essential Cybersecurity Controls (ECC-2:2024) and Data Cybersecurity Controls (DCC) are mandatory for the organisations in their scope, which NCA defines as government entities and organisations that own, operate or host critical national infrastructure, and they apply to AI systems there as to any other technology asset. The Saudi Central Bank's Cyber Security Framework (SAMA CSF) is a sector requirement for the financial institutions SAMA regulates.
The Saudi Data and Artificial Intelligence Authority (SDAIA) and NCA also publish AI-specific documents, and they differ in audience and weight. SDAIA's AI Ethics Principles (2023) set the principles for developing and using AI. Its Generative AI Guidelines for Government (2024) are addressed to government entities and state that their employees must not enter data classified Restricted or higher, under the National Data Management Office (NDMO) classification, into generative AI tools; its Generative AI Guidelines for the Public (2024) are advisory. NCA's Draft AI Cybersecurity Guidelines (AICG-1:2026), put out for public consultation in July–August 2026, are still a draft: they show the direction of travel and create no obligation. We establish which of these apply to you and assemble the evidence; we do not certify compliance, give legal opinions or implement technical controls.
How we work
- 1
Inventory and scope
We list the AI in use: systems you have built, tools you have bought, AI features vendors have added to software you already license, and planned projects. For each we record the owner, purpose, data, users and provider, then establish which requirements apply to you based on your sector, your type of organisation and the data you process.
- 2
Classify and write
We classify each system by risk, then write the policy set, the ownership matrix, the human-oversight procedure and the vendor due diligence questions. Where PDPL requires an impact assessment, we prepare it with your data protection officer. Drafts are reviewed with your legal, risk and security teams and the business owners of each system before approval.
- 3
Map evidence and plan
We link each applicable requirement to the evidence you hold, the gap and the owner who closes it, and set the operating model: who approves new AI use, how the register stays current and when it is reviewed. You receive a 90-day plan. Your data stays yours; documentation and deliverables are handed over as set in the contract.
What is included
AI policy set
Acceptable use for staff, a development policy for teams that build AI, and procurement rules for buying and contracting for it, written to fit your existing policy framework and data classification.
AI system inventory
A register of AI systems, tools and embedded features, including those added to software you already license, with the owner, purpose, data, users, provider and hosting location of each.
Risk classification
A method that rates each system by its purpose, the data it uses, its effect on individuals and whether it only answers or also takes actions, drawing on SDAIA's AI Ethics Principles and, as an international reference, the US National Institute of Standards and Technology (NIST) AI Risk Management Framework (AI RMF 1.0) and its Generative AI Profile.
Ownership and RACI
A named business owner for every system and a RACI matrix across business, IT, security, data protection, legal and risk, so every decision has someone accountable for it.
Human-oversight procedures
For each system, by risk level: which outputs a person reviews before use, which actions need approval, how to override or stop the system, and how those decisions are recorded.
Vendor and model due diligence
Questions and contract points for AI products and model providers on data retention, use for training, processing location, subprocessors, transfers outside the Kingdom, security testing, notice of model changes and exit.
Requirement map with evidence
Each applicable requirement linked to your evidence and gaps: PDPL; SDAIA guidance; NCA ECC and DCC, with the Cloud Cybersecurity Controls (CCC) for cloud services, where you are in their scope; SAMA CSF for SAMA-regulated institutions; and NCA's draft AI guidelines as direction, not obligation.
Data protection impact assessment
An impact assessment for AI processing of personal data where PDPL requires one, prepared with your data protection officer; the legal view remains with your legal counsel.
Operating model and 90-day plan
Approval gates for new AI use, review cycles and reporting to management, with a 90-day plan that names each action and its owner, including technical controls to implement through Secure AI Gateway & Guardrails, Generative AI Data Protection or your own teams.
Frameworks and regulations
We align the service with the frameworks your organisation is subject to.
- PDPL
- SDAIA AI Ethics
- SDAIA GenAI
- NCA ECC
- NCA DCC
- SAMA CSF
- ISO/IEC 42001
- NIST AI RMF
Frequently asked questions
Which Saudi requirements actually apply to our AI?
It depends on who you are and what data your AI processes. If it processes personal data, PDPL applies as law, and a model running outside the Kingdom raises a transfer question. If you are in NCA's scope, as a government entity or an organisation with critical national infrastructure, ECC-2:2024 and DCC are mandatory, with CCC for cloud services; if you are a financial institution SAMA regulates, the SAMA Cyber Security Framework is a sector requirement for you. SDAIA's AI Ethics Principles set principles for anyone who develops or uses AI, its Generative AI Guidelines for Government are addressed to government entities and their staff, its guidelines for the public are advisory, and NCA's AI guidelines are still a draft. We set this out in an applicability statement that names each requirement, its status and why it applies, for your legal counsel to confirm.
Are NCA's AI cybersecurity guidelines mandatory?
No. The AI Cybersecurity Guidelines (AICG-1:2026) are a draft NCA put out for public consultation in July–August 2026, and a draft under consultation creates no obligation. The final text, scope and status are for NCA to decide. We treat the draft as direction: we show where your current controls already point the same way and which gaps would matter if the final text keeps that direction. Your current NCA obligations, if you are in their scope, remain ECC, DCC and, for cloud services, CCC.
Do you certify that we are compliant?
No. DataSec does not certify, attest or declare that an organisation is compliant, and we do not give legal opinions. We give you a requirement map that links each applicable requirement to the evidence you hold, the gaps and the owner of each gap. Your management, legal counsel and auditors reach their own conclusion from it. Where a formal attestation or certificate is needed, it comes from your auditors, the regulator or an accredited body.
We already have ISO 27001 or a GRC programme. Do we need separate AI governance?
Usually not; you extend what you have. AI systems belong in your existing asset register, risk register, third-party risk process, change management and internal audit plan. What is new is the AI-specific content: risk criteria for model behaviour, human oversight, vendor questions about training and model changes, and the AI policies. We add these to your current framework and committees, and propose a separate AI committee or role only where your size or exposure justifies it. If the wider governance framework needs building first, that is our GRC Advisory service.
How do you find the AI already in use?
By combining several sources, because none of them sees everything on its own. We review procurement and licence records, interview business and IT owners, check the AI features vendors have added to software you already license, and identify what development teams have built or connected to models through an API. Staff use of public AI tools is found through network and endpoint discovery, which is part of our Generative AI Data Protection service; if you use it, its findings feed the register. The register then stays current through your procurement and change approvals rather than being a one-off list.
What does human oversight mean in practice?
It means named people can check, correct and stop an AI system at the points where its output matters. For each system the procedure states which outputs a person reviews before use, which actions need approval, what the reviewer must see to judge the output, how to override or switch the system off, and how decisions are recorded. The depth depends on risk: an assistant that drafts correspondence needs less than a system that affects people's rights or triggers actions in other systems. Oversight reduces the effect of errors but does not prevent them, so the procedure also sets how errors are reported and corrected.
What should we require from AI vendors and model providers?
Clear written answers on how your data is handled, and contract terms that hold them to those answers. Ask whether prompts, files and outputs are stored and for how long, whether they may be used for training, where they are processed and by which subprocessors, how personal data leaving the Kingdom is handled, what security testing the product has had, and how incidents, model changes and exit are handled. For software that adds AI features, ask whether each feature can be switched off and whether it changes the data terms you agreed. We provide the due diligence questionnaire and contract checklist; your legal counsel finalises the terms.
Can you prepare us for an ISO/IEC 42001 certificate?
Yes, we prepare you for it; the certificate itself is issued by an accredited body after its own audit, not by DataSec. ISO/IEC 42001 is an international standard for AI management systems, not a Saudi requirement. We assess your current state against it, build the missing elements such as the management system scope, AI policy, risk and impact assessment processes and internal audit, and can carry out a pre-audit review.
Related services
Govern & Comply
GRC Advisory
Policies, procedures and risk management built on NCA, SAMA and ISO 27001 controls.
Govern & Comply
Compliance Assessment
Gap assessment against ECC, CSCC, SAMA CSF and PDPL with a remediation plan.
Secure AI & Automation
AI Strategy & Readiness Assessment
Find the AI use cases worth building: readiness and data assessment, prioritised use cases, a target architecture and a roadmap with budget considerations.
Security Solutions
Generative AI Data Protection
Keep sensitive data out of tools such as ChatGPT, Gemini and Claude, with block and warn policies and incident logging.
Sales
Talk to our sales team
Tell us what you need and we will prepare a proposal for this service, or reach sales directly by call or WhatsApp.
Unified number
9200 33782For general enquiries about our services and for existing clients. Reachable from within Saudi Arabia.
Mobile (calls and WhatsApp)
+966 59 750 4669The direct sales line, by call or WhatsApp: a quick quote or a question about this service, and for existing clients.
Email
info@datasec.sa- Looking for a job at DataSec? Open roles

