Emily Aryeetey

Partner

Emily is an employment partner with experience in advising on employment-related data privacy and protection issues both in the UK and in the UAE (in respect of compliance with UAE federal laws and laws in the common law jurisdictions of the Dubai International Financial Centre ("DIFC") and the Abu Dhabi Global Market). Her experience includes advising multinational clients on the UAE aspect of projects to harmonise global data protection policies; advising employers on complying with data subject access requests; and advising on issues arising during recruitment, in the context of corporate transactions, and on the termination of employment when processing and disclosing data to prospective employers, government agencies, and other third parties.

Emily has helped clients to undertake compliance projects to implement the DIFC Data Protection Law (DIFC Law No. 5/2020) (and its predecessor, DIFC Law No. 1/2007). She has delivered training on these laws to legal practitioners in association with the DIFC Academy of Law (now the DIFC Academy) as part of a team that the Academy formally recognised as 'Specialists in DIFC Data Protection Law'. Emily also contributed to the data protection chapter of 'Laws of the DIFC' published by LexisNexis Middle East, and continues to provide written and podcast commentary on the topic such as on the impact of the GDPR on DIFC Data Protection Law.

Advised and represented a multinational real estate asset management company in respect of a UK ICO investigation regarding a former employee's GDPR data subject rights.
Advised on the alleged breach of the UAE Cyber Crimes Law (Federal Law No. 5/2012 (as amended)) and the UAE Penal Code (Federal Law No. 3/1987 (as amended)) in respect of the unauthorised disclosure of employee photographic personal data, and prospective criminal prosecution.
Advised a leading regional power plant operation and maintenance company on the disclosure of employee personal data to a third party under a disciplinary investigation and mitigating the risk of cyber defamation under the UAE Cyber Crimes Law.
Advised an investment management firm on the data privacy issues of remote working cyber security penetration testing in the DIFC.
Assisted with the review of Neuberger Berman's employee privacy documentation in respect of its DIFC Data Protection Law implementation exercise.
Advised an international bank on its employee retention policy as part of its DIFC Data Protection Law implementation exercise.
Advised on the interplay between UAE data protection laws and whistleblower rights under Dubai Law No. 4/2016 establishing the Dubai Economic Security Centre, the UAE Penal Code, and the DIFC Operating Law (DIFC Law No. 7/2018).
Prepared extensive employee data retention schedules in line with the data protection requirements and limitation periods under UAE federal law and DIFC law.