--- title: Bahrain PDPL Cross-Border Data: ERP Control Checklist url: https://www.erpbahrain.com/compliance/pdpl-cross-border-data/erp-controls/ updated: 2026-10-09 publisher: BAHRAIN ERP (part of Shyphan AI Solutions Pvt Ltd) --- Compliance # Bahrain PDPL Cross-Border Data: ERP Control Checklist A checklist of ERP controls for PDPL cross-border data, to review with your accountant or adviser. Quick answer PDPL Cross-Border Data in Bahrain: PDPL Article 12: transfers outside Bahrain are prohibited unless the destination is on the Authority's adequacy list published in the Official Gazette, or the Authority authorises case by case. PDPL Article 13: transfer to a non-adequate country is allowed with the data subject's consent or on other grounds listed in that Article. - PDPL Article 13: the Authority may authorise transfers to non-adequate countries where the controller shows adequate safeguards, for example by contract, subject to conditions. - PDPL Article 14: prior notice of automated processing to the Authority must include any proposed transfer of data outside the Kingdom (unless a Data Protection Guardian is appointed). - Order 43 of 2022 Article 6 refers controllers to Article 5 of Order 42 of 2022 (transfer outside Bahrain) when contracting external processors. - Sources checked 2026-10-09 This page is part of our Bahrain compliance series. Related topics: [PDPL Access Control](https://www.erpbahrain.com/compliance/pdpl-access-control/), [PDPL Data Retention](https://www.erpbahrain.com/compliance/pdpl-data-retention/). Apply them in [Zoho Books](https://www.erpbahrain.com/zoho/zoho-books/), [Odoo Accounting](https://www.erpbahrain.com/odoo/odoo-accounting/) or [ERPNext Accounting](https://www.erpbahrain.com/erpnext/erpnext-accounting/), and see [all compliance topics](https://www.erpbahrain.com/compliance/). Checked against official sources on 2026-10-09. Source links are listed on this page. Rules change, so check the latest notice from Bahrain's Personal Data Protection Authority before filing. Controls ## Controls to Consider **Control checklist** | Control | Why it matters | | Hosting and provider locations are documented | Reduces errors and supports review | | Transfers are reviewed by your adviser | Reduces errors and supports review | | Provider agreements are kept | Reduces errors and supports review | | Changes trigger a review | Reduces errors and supports review | Records ## Records Involved PDPL Cross-Border Data affects how records are captured, approved and reported in your ERP. The rules come from Bahrain's Personal Data Protection Authority; this page only describes how a system can be set up to support them. - Hosting locations - Service providers - Data transfer records - Agreements Configuration ## Settings to Review Settings to review during implementation. Exact names differ by platform. - Hosting register - Provider register - Transfer log - Review routine Setup ## How to Set Up PDPL Cross-Border Data in an ERP **Setup steps** | Step | What to do | | 1. Confirm | Confirm the current requirement for PDPL cross-border data with Bahrain's Personal Data Protection Authority | | 2. Map records | Map hosting locations, service providers, data transfer records to ERP fields | | 3. Configure | Set up hosting register, provider register, transfer log | | 4. Add controls | Enable the controls above, with approvals and logging | | 5. Test | Run the scenarios below with sample data and compare with expected results | | 6. Document | Record settings, owners and the review rhythm, then train users | Testing ## Test Scenarios Before Go-Live **Test scenarios** | Scenario to test | Expected result | | Try to break this control: hosting and provider locations are documented | The system blocks or flags it, and the attempt is logged | | Try to break this control: transfers are reviewed by your adviser | The system blocks or flags it, and the attempt is logged | | Try to break this control: provider agreements are kept | The system blocks or flags it, and the attempt is logged | | Try to break this control: changes trigger a review | The system blocks or flags it, and the attempt is logged | | Run the process end to end with sample data | Reports reconcile with the transactions entered | Ongoing ## Review Rhythm **Suggested review rhythm** | When | Review | | Before go-live | Confirm requirements with the authority or your adviser; test with sample documents | | Monthly | Reconcile reports to filings or statements; review exceptions | | Quarterly | Review user access, approvals and changes made to settings | | After a rule change | Update configuration, retest and record the change | FAQ ## Compliance Questions - Where do these requirements come from? From official publications of Bahrain's Personal Data Protection Authority, linked on this page - Who sets the rules for PDPL cross-border data? The rules come from Bahrain's Personal Data Protection Authority. Always check current official sources. - What records are involved in PDPL cross-border data? Hosting locations, Service providers, Data transfer records, Agreements. - Can BAHRAIN ERP configure our system once rules are confirmed? Yes. We configure and test the system against the requirements your adviser confirms. - What do the official sources say about PDPL cross-border data in Bahrain? PDPL Article 12: transfers outside Bahrain are prohibited unless the destination is on the Authority's adequacy list published in the Official Gazette, or the Authority authorises case by case. PDPL Article 13: transfer to a non-adequate country is allowed with the data subject's consent or on other grounds listed in that Article. PDPL Article 13: the Authority may authorise transfers to non-adequate countries where the controller shows adequate safeguards, for example by contract, subject to conditions. - Which records does PDPL cross-border data involve in an ERP? Hosting locations; Service providers; Data transfer records; Agreements. - Which ERP controls support PDPL cross-border data? Hosting and provider locations are documented; Transfers are reviewed by your adviser; Provider agreements are kept; Changes trigger a review. - Which ERP settings should be reviewed for PDPL cross-border data? Hosting register; Provider register; Transfer log; Review routine. Have More Questions? Book A Free Consultation [ Talk to Us ](https://www.erpbahrain.com/contact.html) Or, Email us at contact@erpbahrain.com ## Related Pages - [PDPL Cross-Border Data guide](https://www.erpbahrain.com/compliance/pdpl-cross-border-data/) - [All compliance topics](https://www.erpbahrain.com/compliance/) - [Bahrain PDPL Cross-Border Data: System Configuration Requirements](https://www.erpbahrain.com/compliance/pdpl-cross-border-data/system-configuration/) - [Bahrain PDPL Cross-Border Data: Frequently Asked Questions](https://www.erpbahrain.com/compliance/pdpl-cross-border-data/faq/)