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))
Records collected to answer a support ticket or run an account may not later be used in a manner incompatible with that purpose, though a similar or close purpose is allowed. Licensing them to a third party to train a model is, on my reading, neither similar nor close, so it needs a fresh consent under Article 4. Data no longer needed for its purpose may be kept only once the person's identity is concealed under the law's 'Anonymization Mechanism'.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Personal Data shall be collected for a specific and clear purpose. It shall not be processed at ... any later time in a manner incompatible with such purpose. However, it may be processed if the purpose is similar or close to the purpose for which this data is collected. ... Personal Data shall not be kept after the purpose of its processing has been exhausted. It may be kept if the identity of the Data Subject has been concealed”
Where it was read
Also read from the same source
- 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 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))
- 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)
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