UAE Personal Data Protection Law, Article 1: what personal data is (voice included) and what anonymization means (Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, Art. 1 (definitions of Personal Data and Anonymization))
Personal data includes data that can identify a person indirectly by linking, and the listed identifiers include voice, image and electronic identifier, so call recordings, chat logs and CRM notes are covered. The law's own standard for anonymization is strict: the person must be impossible to identify 'in any way whatsoever', and a separate, weaker category (pseudonymisation, where extra information can still link the data back) stays personal data. Data that truly meets the anonymization definition is no longer about an identifiable person, which is my reading of how the definitions fit together; the law does not say in so many words that anonymised data is outside it.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
“Any data related to a specific natural person or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements such as his/her name, voice, image, identification number, his/her electronic identifier, his/her geographical location ... Processing which is performed on Personal Data in a way which leads to the anonymity of the Data Subject, not linking and attributing such data to him/her and the inability to identify him/her in any way whatsoever”
- UAE Personal Data Protection Law, Article 4: no processing without the owner's consent, with a closed list of exceptions (Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, Art. 4)
- UAE Personal Data Protection Law, Article 5: collect for a specific purpose, no incompatible later use, keep only if anonymised (Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, Art. 5(2) and 5(7))
- UAE Personal Data Protection Law, Articles 22 and 23: sending personal data outside the UAE (Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, Arts. 22(1) and 23(1)(a)-(b))
- UAE Personal Data Protection Law, Articles 2(2)(g) and 28: free zones with their own data law are outside, Executive Regulations due within six months (Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data, Arts. 2(2)(g) and 28)
It is shown on its own, not counted into a figure.
Cited in this guide