All Posts By mahmood

Bahrain Personal Data Protection Law coming into effect

Some of you may know that I have been on a campaign to protect data, personal data specifically, from misuse and my demands for legislation to strenuously protect that data to prevent its misuse, and to enact stern penalties on those who do misuse personal information.

On August 1, 2019, the Bahrain’s Personal Data Protection Law (PDPL) comes into effect. And it seems to address my raised concerns, which is a relief not just for me, but for everyone in Bahrain.

The issue is, although the law will come into effect and obviously organisations large and small will be held liable for its implementation, the Data Protection Agency doesn’t actually exist! More-over, no ministry or minister has been put in its charge. It’s just 22 days for the law to come into effect, and it looks like its going to be a difficult breach birth.

In any case, to introduce the law and to help businesses understand their responsibilities and make arrangements to stay within its limits, the Chamber of Commerce held a seminar this morning at its premises which was really well attended. The number of people attending is a testament on how businesses in Bahrain are seriously taking this matter. The presentation was done by keypoint‘s Mr Srikant Ranganathan, their senior director of IT consulting and it was quite comprehensive.

What is this law and what does it contain? keypoint and KPMG have good short guides which are worth reading (click the links to download pdfs). From keypoint’s document:

Bahrain issued Law 30 of 2018 – the personal data protection law (PDPL) – on 19 July 2018, with the law coming into effect from 1 August 2019. The PDPL applies to any entity processing personal data wholly or partly by automated means – as well as the manual processing of personal data as part of an organised filing system.

The PDPL require a range of changes to the way businesses process personal data in Bahrain. Entities are required to seek prior approval from the relevant data protection authorities (DPAs) when collecting, processing and storing personal data. The PDPL imposes new obligations on how businesses manage data, including ensuring that personal data is processed fairly, that data owners are notified when their personal data is collected and processed, that collected personal data is stored securely, and that data owners can exercise their rights directly with businesses.

There are also hefty fines for breaching the law and its provisions, some criminal and others are administrative and are cumulative:

The PDPL enforces a range of criminal and administrative fines:

  • Criminal offences include the processing of sensitive personal data, the transfer of personal data outside Bahrain, and the failure to notify as required – fines of up to BD20,000 or imprisonment for up to one year
  • Administrative fines – up to BD20,000 (one- off fines) or daily penalties of up to BD1,000 (may increase for repeat offences)

The law provides for the protection of “personal data” and what it terms “sensitive personal data“. These are defined as:

Personal data: Any information of any form relating to an identified or identifiable individual, either directly or indirectly, particularly through personal ID numbers or physical, physiological, intellectual, cultural or economic characteristics or social identity.

Sensitive personal data: Any personal information that reveals – even indirectly – an individual’s race, ethnicity, political or philosophical views, religious beliefs, union affiliation or criminal record – and any data related to health or sexual activities.

I think this is really good news for all of us. Finally we have a law – once its Agency actually comes into existence – that will protect our data. And this one is actually stricter than the European GDPR, which is also good news not only for individuals, but also for businesses wanting to establish entities in Bahrain. This is such a crucial issue, that if trust is established for the sanctity of this sensitive information, businesses will want to establish and invest in this country. Read the article by Khaled Alrumaihi of the EDB which explains this issue more.

Download the Bahrain Personal Data Protection Law (PDPL) courtesy of keypoint

The obligations of this law forces companies to be better and respect personal information, something which they have not been able to do because of the non-existence of any penalties for misusing collected and processed information. For instance, businesses routinely demand your national ID number (CPR) without having to have any conceivable reason to do so. Also, they would insist on getting your mobile number, but never tell you that they will be using both to send you unwanted marketing messages. With this law, they have to get your express approval before using your data, and you can demand that they show you what data they have in their databases about you, something you can demand that they delete it and they have to oblige. Beautiful. I look forward to the day where we can gain access to a building – for instance – without having to surrender our ID card first. This to me is not only scary (as it is open to misuse) but is also disgusting.

Before any organisation can collect and process your data, they have to gain the express permission of the DPA (when it is formed, of course! now we’re in limbo) which has a plethora of requirements before permission is granted, chief amongst these of course is the assurance that the organisation will look after and secure your data. I wonder how they will deal with cold stores who provide the service of printing the data contained in your national ID card! That too is a very worrisome affair. Making such data so easily available must ring bells.

So what are the obligations under this law?

The key obligations are:

Many of the obligations placed on “data managers” (controllers) will be familiar to organisations that operate under data protection laws in other parts of the world, including requirements to process data fairly and lawfully, to collect personal data for legitimate, specific and clear purposes and to ensure that data is adequate, relevant and not excessive as to the purpose for which it was collected.

Data cannot be processed without the consent of the relevant individual (data subject) unless it falls within one of the five grounds for processing in Article 4 of the Law. These grounds include the performance of contracts or legal obligations, protecting the data subject’s vital interests and safeguarding the data controller’s legitimate interests. There are derogations for the processing of personal data for journalistic, artistic or literary purposes and more stringent rules applying to the processing of “sensitive personal data” (i.e. personal data that directly or indirectly reveals racial or ethnic origin, political or philosophical views, religious beliefs, trade union membership, criminal record, health or sexual condition).

One interesting feature of Bahrain’s legislation is the role of the ‘Data Protection Supervisor’. This is an accredited third party that may be appointed by data controllers at their discretion or, in some cases, at the direction of the data protection authority. The Data Protection Supervisor must exercise its role in an “independent and neutral manner” (unlike, for example, the data protection officer appointed by European entities under the GDPR). Its responsibilities include monitoring and verifying the data controller’s compliance with the law, supporting the data controller in exercising its rights and performing its obligations, maintaining a register of processing, and coordinating between the data protection authority and the data controller.

The Law prohibits the transfer of personal data outside Bahrain to jurisdictions that are not approved by the data protection authority unless the data subject provides consent or the transfer falls under a specific derogation, including transfers necessary for the performance of contracts, protection of the data subject’s vital interests or preparing, pursuing or defending a legal claim. The Law also requires data controllers to enter written contracts with third parties that process personal data on their behalf (data processors). However, there is no mandatory data breach notification provision in the Law. [source: Clyde & Co]

What should entities do now?

According to keypoint:

To comply with the PDPL, organisations must:

  • Determine what personal data they acquire and process
  • Show they meet the requirements for processing personal data
  • Apply measures to protect data against unintentional or unauthorised destruction, accidental loss, unauthorised alteration, disclosure or access, or any other form of processing
  • Show how they ensure confidentiality when processing data
  • Appoint data protection supervisors to liaise with, or report to, the DPA as and when required

I’m sure there are quite a number of steps to action before it becomes the norm for people and entities to value the privacy of information, and as importantly, to make it a habit to seek approvals before using such sensitive data. It will also be a good day when people in Bahrain object to blindly hading over their personal information including their ID card to anyone who asks.

One thing that I would like to see added to this law immediately is to require entities who suffer any breach of such information to notify their user-base whose information they were entrusted with, and to make public their findings immediately. At the moment, they are not required to divulge any breaches, which – to me at least – impacts the trust that this whole operation requires.

This law is very welcome.

Now I’ve got to go and ask specific permission of those in my marketing database that they would actually like to hear from me from time to time. I won’t be offended if they choose to unsubscribe. I’ll just work harder at gaining their trust and to provide them enough value for them to willingly subscribe to my marketing efforts.

Well done Bahrain. It is high time that we have such a law in place.

I just hope its implementation will be strictly enforced, and that it doesn’t end up just ink on paper.

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Estoy disfrutando español

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I started Spanish lessons about a year ago and am really enjoying it. Our class is small, just about 7 people so we have almost a one-to-one relationship with our teacher Niurka who is a Cuban married to a Bahraini. We take the lessons every Saturday morning at the Hiraf Aldiyar in Muharraq. It’s part of the Shaikh Ebrahim conglomerate.

I’m going to write some more about my experience with this later, for now, I want to share with you this week’s homework, which is writing a postcard to a friend telling them what I’ve been up to.

José Feliciano
San José, CA

Querido José:

El verano en Bahrein es muy calor. La temperatura esta poco menos que el infierno! Hay porque permanecer en el interior. El perro murio pero se secó en un día y no hay malos olores… !Pequeñas misericordias!

Comó estás?

What do you think? Shall I continue with Spanish?

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Childhood memories via Tuc biscuits

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How many of you remember these?

If you do, do you also remember the taste of these salty biscuits dipped into sweet milky tea for breakfast? Or the extra salty taste of them sandwiching Kraft cheese out of glasses which are invariably upcycled into defacto tea glasses?

I do. And I the other recipes we subjected these tasty delights to as well.

I remember going through most of a packet in one sitting. The one thing I hated about them though is ultimately they form a putty inside one’s mouth between the gums and the cheek, resulting in one either washing one’s mouth to expel the stuff, getting one’s tongue to work extra hard to dislodge it or poke one’s finger in all around the offending areas to mine the putty out… only to ingest it again to complete the meal!

I came across this at IKEA this afternoon. I have no idea why they were their. I assume they’re a Swedish product?

I don’t know. Regardless, thank you IKEA for this trip down memory lane!

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Stoked! The cycad is alive :)

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Gardening is not something I thought of for most of my life. I enjoyed seeing plants, but beyond taking pleasure in that, I was just like anyone else I suppose. Revel in the moment, and move on to other things.

This changed when I bought my first house. It welcomed hands-on involvement with its large garden space, and more importantly I think, it was mine. That changed the perspective considerably. Slowly, with time, I gained the gardening experience and driven by my curiosity, I delved into plant science because I wanted to discover how to care for them and make them thrive.

On selling that house, I hoped that the new owners would take care of the garden, and enjoy it as much as I had. I know from talking to the new owner from time to time, that this wish had come true, and that makes me very happy.

I bought a smaller house with a much smaller garden plot. Nevertheless, the pleasure of gardening persists even in the smallest of spaces. As long as the passion is present, then I knew that the pleasure of designing, creating, working and maintaining that space will propel me forward and give me a lot of rewards for my efforts. So once I had the design approximately set in my mind for the new plot with a couple of earmarked plants from the old garden, I set about creating that new haven.

Gardening is a gamble sometimes. You do your best and create as many conditions for success as possible, yet some plants will flourish while others will surprisingly die, regardless of the effort you put it. This is nature and I’ve learn to accept and respect it.

But gardening is also all about hope! That’s why we gardeners talk to our plants, give them names and chastise them sometimes to do better. My children! What can I say…

One of the plants I decided to bring with me was a well established and healthy cycad. The plant is about 20 years old if not older, so yanking it out of its established space in the old garden and plonking it in the new one was a big gamble that required an awful lot of hope. .

This is how it looked in its original location:


The Cycad in its original place in my old garden in Barbar, Bahrain

See how glorious and happy she was?

Well, after planting it in its new home, it wasn’t a happy cookie. It soon went into shock and became yellow, dry and sad even after a few months after re-planting. It required all the hope and positive energy I could muster to just leave it where it was… and will myself to be more patient. The number of times I got close to yanking it and throwing it out were numerous, but something held me back.. This is how it faired by March 3rd, 2019 in its new location. See how wilted it looked?

And believe me you won’t want to look at its pictures in May as it was almost completely yellow, and it had lost most of its fronds.

Preparing for the oppressive heat of the summer, I covered it with 50% shade and increased its irrigation a little bit. I also threw in a bit more compost around it (I know this is not normally done in the summer, but I really didn’t have anything to lose at that point). Clinging to hope makes you do stuff you don’t normally consider… that’s why hope is a very dangerous thing!

Well that hope was well founded! Or our prayers were entertained!

Yesterday morning I went to say hello to it on my way to work, and I was so thrilled to witness new growth when I peeked under its veil!

Look! Look!

Those little fluffy things in the middle are fronds in the making! I hope I’m not getting excited too soon (fat chance of that ever happening!!!) but this is the best sign I’ve had of it actually being alive.

I’m so grateful. This makes me so happy!

Hope, you see, is a fantastic thing!

Have a lovely weekend all. xx

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Is this thing on?

Quite a number of things changed in my life over the past few years. The last year or so has been especially eventful, so much that looking at a few of the most recent posts in the Den, it begged the question of whether I should delete everything and start fresh, or keep the legacy and just carry on?

For now, I’ll just carry on. The wealth of history contained in this database is worth preserving at least for interest’s sake.

One distinct thing that has changed in me is my distaste for politics. Looking back at a few articles I wrote, I now ask myself why I allowed myself to be so worked up about issues. Fully realising even then that mine is an insignificant force that will not be able to influence much change. Don’t get me wrong though, I’m happy that I voiced my opinion; however, with my increased skepticism since then, and my belief that the world is utterly crazy and not worth getting worked up about – realising of course that ‘this too shall pass’ and people rarely age beyond 90, then things will definitely change, regardless of how people attach themselves to the idea of immortality.

Anyway, this is a meandering rambling post to kick the tyres and get myself again into the habit or writing and posting.

Chat soon.

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شكراً زايد

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لم ألتقي بأحد في البحرين الذي فعلاً يجسد قصد #فريق_البحرين مثل زايد الزياني. التواصل معه سهل و رده حازم وسريع.

لأسرد لكم قصة حدثت معي هذا الأسبوع لأوضح سبب إعجابي بهذا الشخص…

عندي شركتين، واحدة مؤسسه والثانية محدودة المسؤلية. في أثناء تقديم معاملة لواحدة منهما، اتضح ان هناك مخالفة على الأخرى لتأخرنا في تحميل الحسابات النهائية، فلهذا السبب تم إيقاف معاملات المؤسسة الأخرى لتصحيح الوضع. ليس لدي أي اعتراض على الخلل، بينما أعترضت وبشدّة لدمج المؤسستين هكذا مع العلم أنهما يجب أن يكون لكلٍ منهما شخصية إعتبارية قانونيا. ففي المنطق يجب ألا يؤثر أي خلل أو قضية أو مطالبة على أيٍ من المؤسسات على الأخرى.

فكتبت للوزير الزياني عن إعتراضي عن طريق الواتس آب واستبشرت خيراً لمَ وجدته قد قرأ الرسالة، ولكن لم يكن في حسباني رده الفوري الذي يوافقني الرأي وأخبرني أن الوزارة فعلاً على علم بهذه الثغرة القانونية وأنهم ينتظرون نشر القانون الجديد الذي سيعالج هذه الحالة في الجريدة الرسمية. فإستسمح مني بعض الوقت للدراسة. وفي خلال أقل من ساعة خابرني أن القرار قد أُصدر فعلاً ونُشر في الجريدة الرسمية الأسبوع الماضي وأن معاملتي ستسير ميسرة قريبا.

ما بارحت الساعة وإلا الاستاذ علي مكي، وكيل الوزارة، يتصل بي ويطمئنني أن المخالفة قد رُفعت فعلاً ومعاملتي سارت بسلاسة الى النقطة التاليه، وإن هذا التغيير في القانون هو سارياً على الجميع فوراً.

أعزائي، الحق يقال.. ففي أي دولة في العالم يتسنى لشخص عادي، وتاجر صغير كذلك الإتصال بوزير رفيع و يُسمع و يُجاوب بهذه الطريقة و بطول بال وأريحية؟

.فالشكر موّصل للأخ الوزير القدير زايد الزياني وطاقمه الحرفي وهنيئاً للبحرين لوَعي وحرفية وتواضع رجالاتها.

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Outliers. How Success is a Community Sport

Outliers by Malcolm Gladwell is an interesting read. It provides a different interpretation on the reasons for success and emphasises the fact of how wrong the adage “self made man/woman” is.

Gladwell argues that success is never overnight but is deeply dependent on several factors from culture, society, education, and even the year of birth and then the preceding hard and dedicated work of some 10,000 hours required to achieve mastery. Then and only then having the presence of recognising and tenaciously gripping opportunities to make them stressful.

He outlines several fundamental research to support his theories and observations, the most eye-opening for me was how there are essentially only two ways children are raised, in this context, of that how poor families tend to raise their children and hour to the rich did and how those affected the psyche and ultimately the opportunities that become available for either in their lives.

There are so many lessons and thoughts to evaluate and gain from in this book. I very much recommend it.

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Uncommon Type by Tom Hanks

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Tom Hanks doesn’t much act in his movies and is not type-cast. He is just a naturally good human being! That’s the simple fact, and his writing completely confirms this too.

As I read his stories in Uncommon Type, I was almost urging him to put in some drama at this point, or do a plot twist there, to no avail though, as the stories are just “nice”, and some would say rather bland.

We’re trained to expect and demand drama in fiction and that’s what’s dished out to us. However, reading beyond that expectation in the first two or three stories, I find myself accepting that yes, the world indeed has more good than bad, and people are naturally kind. By then, I was cringing whenever I came across a cuss word – sparingly used through his text as they are – I actually felt that he was compelled to use them to show some form or “badness”. I’m happy to say that even with those, he can’t be, not with his kind and trusting nature.

Later on by the fifth or sixth story, the pace was picking up, and my realization that no earth-shattering drama is about to happen, made me relax even more. That relaxation led to sinking even deeper in my seat as I continued reading this nice book. Even his attempts at injecting a twist on the story, almost always at the very end with the last sentence, didn’t shake that sense of goodness in the world.

Uncommon Type is light reading that doesn’t tax one’s brain much, and some of its stories would certainly benefit from better plot twists and drama to make them even more enjoyable.

What you get with this book, I guess, is the calming influence one might expect from Xanax.

Thank you Mr Hanks.

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Timely Serendipity, the Book of Joy

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The Book of Joy is a life changing book.

Do you believe in serendipity? I certainly do after picking up this book. It was like the universe was aligning just at the right time, and presenting me with this book because I needed its teachings most. This book was bought by my lovely wife while we were on a recent trip to Nepal. From a Tibetan bookshop too!

At a time when more things were going wrong than right. At a time of change in my life. This book provided a global perspective that I was slowly missing. Focusing on my own problem rather than putting them in context. Focusing inward than outward. This book and its authors; two heroes of mine, His Holiness the Dalai Lama and Archbishop Desmond Tutu, have re-centered me and got me to focus on things larger than me. Through their shared wisdom, they are guiding me to find joy. Joy that was illusive over the past score years. And their wisdom and experiences offer a verifiable guide on how one might attain lasting joy and all the peace and tranquility that it brings.

I highly recommend this book and am eternally grateful to its authors for bringing it to us. I’m also very grateful to my wife who picked it up and allowed me to read, and now benefit from it.

Blessings to you all. I wish you joy and happiness.

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