Egypt: Personal Data Protection Center released Data Subject Consent Guidelines

On 26 January 2026, the Personal Data Protection Center (PDPC) released the Data Subject Consent Guidelines, Version 1.1, setting out non-binding guidance on consent as a lawful basis for processing under Article 3 and Article 6 of the Personal Data Protection Law enacted by Law No. 151 of 2020 and the Executive Regulations issued by Decision No. 816 of 2025. The Guidelines identify six lawful bases and explain that consent requires a clear affirmative action and must be assessed case by case, including consideration of power imbalance and processing that occurs regardless of refusal or withdrawal. They define valid consent as personal, explicit, informed, specific and freely given, and impose additional written consent and legal guardian consent requirements for sensitive personal data and children’s data, including age thresholds at 15. They specify mandatory consent request content, Arabic language and design requirements, prohibit presumed consent and dark patterns, require granular and separate requests, regulate consent management and refreshing, establish detailed withdrawal rights and post-withdrawal obligations, and mandate comprehensive consent record keeping available to the PDPC upon request.