The Registration Authority of ADGM has amended the Data Protection Regulations 2021 to introduce the Data Protection Regulations (Substantial Public Interest Conditions) Rules 2025 (the “Substantial Public Interest Rules”). The enactment of these Rules follows the conclusion of Consultation Paper No. 6 of 2025 and reflects ADGM’s ongoing commitment to maintaining a data protection framework that is both internationally aligned and responsive to evolving societal needs.
The Substantial Public Interest Rules provide greater clarity on the processing of Special Categories of Personal Data under defined public interest grounds. These changes are particularly relevant to sectors such as insurance and education and are benchmarked against global best practices.
Key features of the Substantial Public Interest Rules include:
- Establishing conditions for insurance companies to process Special Categories of Personal Data for insurance purposes where such processing serves a substantial public interest.
- Introducing clear definitions of “insurance contract” and “insurance purpose” to ensure consistency across the sector.
- Providing safeguards that allow the processing of Special Categories of Personal Data without consent when necessary to protect children or individuals at risk of emotional or physical harm.
- Clarifying the criteria for determining when individuals aged 18 or over may be considered “at risk” and thus eligible for protection under these Rules.
These Rules are designed to support ADGM’s expanding jurisdiction, including Al Reem Island, by ensuring robust protections for vulnerable individuals whilst facilitating responsible data use in key sectors.
Commenting on the enactment, H.E. Rashed Al Blooshi, CEO of Registration Authority at ADGM, said: ” ADGM’s data protection framework is built on the principles of accountability, transparency, and public trust. These new rules reinforce our commitment to protecting individuals, particularly the most vulnerable, while enabling responsible data use across sectors. We remain focused on ensuring our regulations evolve in line with both global standards and local needs.”
These amendments mark a significant step forward in balancing the need for responsible data processing with the imperative to safeguard sensitive personal information. By clearly defining the conditions under which special categories of data can be processed, ADGM is further strengthening protections that serve the public interest while supporting critical sectors such as insurance and education.
The enacted version of the Substantial Public Interest Rules is publicly available and can be viewed here: [Substantial Public Interest Rules 2025].