الحماية الإدارية للبيانات الشخصية بين التشريعات الوطنية والمبادئ الدولية للحوكمة: دراسة مقارنة

This study examines the administrative protection of personal data within a comparative framework between national legislation in the United Arab Emirates and the Arab Republic of Egypt and international governance principles. This study examines the growing strategic importance of data as a fundamental pillar of the digital economy and a sensitive area of ​​human rights. The study adopted a comparative analytical approach supported by critical institutional analysis, where Federal Decree-Law No. (45) of 2021 in the UAE and Law No. (151) of 2020 in Egypt were analyzed and compared with the European General Data Protection Regulation (GDPR), which constitutes the most advanced model globally. The results showed that Emirati legislation is characterized by comprehensiveness and the recognition of direct individual rights such as the right to rectification, erasure, and objection, while Egyptian legislation focused on an institutional approach by establishing a Personal Data Protection Center with broad licensing and oversight powers. Despite this divergence in legislative philosophy, the study reveals that both models face similar challenges, namely the weak independence of administrative bodies, insufficient technical capabilities, and limited administrative penalties compared to the stringency of European sanctions, which impose strict and deterrent obligations on violating institutions. It also reveals that governance principles such as transparency, accountability, and fairness are partially reflected in legal texts but have not yet been transformed into integrated institutional practices capable of ensuring compliance. The study concludes that administrative protection in the UAE and Egypt is still in its infancy, requiring legislative and institutional reforms, most notably strengthening the independence of oversight bodies, enhancing the level of penalties to be deterrent, developing human and technical capabilities, and activating regional and international cooperation to address cross-border challenges. The study thus provides a scholarly contribution that fills a gap in the Arab literature and links national protection with international governance standards.