DuoKey
Compliance

UAE PDPL

Federal Decree-Law No. 45 of 2021 on personal data protection. Security measures and cross-border transfer, with customer-held keys as architecture not legal conclusion.

Requirements

What the regulation expects

Federal Decree-Law No. 45 of 2021 has been in force since 2 January 2022. Read operative articles on security measures and cross-border transfer from the official legislation portal before quoting them in a bid. Customer-held keys are an architectural input to security and transfer analysis. Whether a given design satisfies the law for a dataset is a legal determination, not a product claim.
What the regulation expects

Federal personal data protection since January 2022

Applies to processing of personal data through electronic systems inside or outside the country.

Security measures

Controllers need technical and organisational measures that actually protect personal data. Encryption with keys you govern is one of them.

Cross-border transfer

Keeping keys in the UAE while ciphertext sits in a global cloud is a common pattern. Supply location attestation to counsel; do not treat it as automatic compliance.

Alignment with sector rules

Healthcare (ADHICS), finance (CBUAE) and Dubai DESC often apply in parallel. Key architecture should satisfy the strictest applicable instrument.

Solutions

How DuoKey supports the framework

OpenBAO + DuoKey SD-HSM

On-premise or in-country vault with tamper-evident trail of every key access.

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Microsoft 365 DKE

Outer key held under entity control so the SaaS host cannot unilaterally decrypt.

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AWS XKS / HYOK

Keys outside the cloud provider as an input to transfer assessment.

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Key themes

Where independent key control fits

Quote operative articles from the official text. Product mappings stop at architecture and evidence.

Security measures for personal data

Encryption with customer-held keys, enforced access control and a tamper-evident trail of access to key material.

Cross-border transfer architecture

Key location attestation and deployment topology supplied to the customer's legal transfer assessment. Not a substitute for that assessment.

Resources

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