DIFC Issues Landmark Adequacy Decision Regarding The California Consumer Privacy Act

On August 7, 2023, the Commissioner of Data Protection of the Dubai International Financial Centre (the DIFC), a financial free-zone in the United Arab Emirates, issued the first adequacy decision regarding the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020, the CCPA), recognizing the essential equivalence of the CCPA with the DIFC Data Protection Law (DIFC Law No. 5 of 2020, as amended the DIFC DPL). Importantly, the issuance of the decision helps to facilitate the transfer of data between the DIFC and entities based in California in accordance with the DIFC DPL without requiring such entities to apply additional contractual measures. Furthermore, the Commissioner's press release expressly notes that the issuance of the adequacy decision may serve as a precedent for the DIFC establishing a similar relationship with other U.S. states. California is now one of 49 countries, jurisdictions or organizations subject to an