Omnibus data privacy laws are few and far between in the Middle East. None of the six states of the Gulf Co-Operation Council (GCC)—which comprises Saudi Arabia, Kuwait, Oman, Qatar, Bahrain and the United Arab Emirates—have issued national privacy legislation, although several have draft regulations under consideration.

By contrast, the financial “free zone” jurisdictions of Dubai International Financial Centre (DIFC) and Qatar Financial Centre (QFC) have both adopted European-style data protection regulations.

Abu Dhabi Global Market (ADGM) is the proposed new financial services free zone on Al Maryah Island in the UAE’s capital city of Abu Dhabi. Like DIFC and QFC, it will have independent courts of first instance and appeal to oversee the jurisdiction of the free zone.

Unlike its more established neighbours, though, ADGM has decided not to introduce general legislation regulating the handling and processing of personal data in the first wave of draft regulations issued for public consultation this month.

There are, however, proposals to place certain limited obligations on employers operating in ADGM in relation to personal data relating to their employees.