With Ramadan coming to an end and Eid al-Fitr expected on 30/31 March 2025, and Eid ul-Adha on 6 June 2025, many organisations are considering how best to support Muslim employees. Flexible working hours, awareness of fasting, and time off for religious observances are often a focus for organisations. But one important area is frequently overlooked—how organisations handle religious data.
Why Data Protection Matters During Ramadan and Eid?
Religious belief is classified as a special category data under GDPR (Article 9) in the UK and Europe, meaning it requires extra protection. Many organisations collect this data without fully realising the risks. Whether it’s through HR systems, equality reporting, or even well-meaning Eid messages, it’s crucial to ensure any data collection is necessary, proportionate, and lawful.
Similarly, data protection laws across the UAE and GCC—including the UAE PDPL, DIFC and ADGM regulations, Saudi Arabia’s PDPL, and similar laws in Bahrain, Qatar, Oman, and Kuwait—classify religious beliefs as sensitive personal data, requiring strict safeguards. These laws include:
United Arab Emirates (UAE) – Federal Law No. 45 of 2021 on Personal Data Protection (PDPL)
Bahrain – Law No. 30 of 2018 – Personal Data Protection Law (PDPL)
Oman – Royal Decree No. 6/2022 – Personal Data Protection Law (PDPL)
Saudi Arabia – Personal Data Protection Law (PDPL)
Dubai International Financial Centre (DIFC) – Data Protection Law No. 5 of 2020
Abu Dhabi Global Market (ADGM) – Data Protection Regulations 2021
Qatar – Law No. 13 of 2016 – Personal Data Protection Law
Kuwait – Data Privacy Protection Regulation
These regulations mandate that religious data should only be processed with a clear legal basis, ensuring organisations remain compliant while respecting employee privacy.
Are You Collecting More Religious Data Than Necessary?
It’s easy to collect religious data without intending to. Common scenarios include:
- Annual leave records – Employees requesting time off for Eid.
- EDI (Equality, Diversity & Inclusion) data – Religious beliefs recorded for diversity reports.
- Event planning – Sending Eid greetings or inviting specific individuals to celebrations.
- Performance reviews – Managers noting Ramadan observance or fasting in feedback.
At first glance, these practices may seem harmless, even positive. But under data protection laws, any data identifying someone’s religion requires a clear legal basis or explicit consent. This means organisations must carefully assess whether collecting and storing such data is truly necessary.
Consider these key questions:
- Do we actually need this data? Could a simple ‘personal leave’ request replace recording ‘Eid leave’?
- Where is it stored? If religious affiliation is logged in an HR system, is access restricted?
- Are employees aware? Have they given clear, informed consent?
Inclusivity Without Overstepping Data Protection
Supporting religious inclusion doesn’t mean tracking personal beliefs. Instead, organisations can take a privacy-conscious approach:
- Anonymise data – If collecting religious data for reporting, make it voluntary and anonymised.
- Offer flexible leave without labels – Avoid recording ‘Eid leave’; instead, use neutral personal leave policies.
- Keep event invitations open – Instead of targeting individuals based on assumed religious identity, invite all staff.
Consider this scenario: An employer wants to acknowledge Eid celebrations among staff during the festive period. They review leave records and send a company-wide Eid greeting only to those who have previously taken time off for Eid.
Instead, organisations can take an inclusive but non-intrusive approach by sending open invitations or greetings to all employees.
Practical Steps to Get It Right
- Review HR Data Practices – If religious affiliation is recorded, ensure its lawful, necessary, and stored securely.
- Train Managers on Privacy & Inclusion – Educate leadership on balancing inclusivity with data protection.
- Be Mindful of Internal Communications – Ensure inclusivity initiatives do not inadvertently lead to profiling or data risks.
- Respect Individual Preferences – Not all Muslims celebrate Eid the same way. Some may prefer not to disclose their religious beliefs at work.
Dos and Don’ts for Handling Religious Data During Eid
✅ Dos
- provide flexible time off for Eid without requiring employees to disclose religious details.
- obtain clear, informed consent before collecting any religious data.
- ensure sensitive data is stored securely and only accessible to authorised personnel.
- communicate with the entire workplace to create an inclusive environment during Eid.
- update privacy policies to reflect the handling of religious data and ensure transparency.
❌ DONTs
- collect religious data unless it is necessary for operational purposes.
- make assumptions about who is observing Eid or how they celebrate.
- store religious data without proper safeguards.
- share religious data with anyone who doesn’t need to know.
- forget to provide training to staff about data protection and privacy.
Building an Inclusive and Privacy-Respecting Workplace
Eid is a time of community, generosity, and reflection. Organisations should support employees in a way that aligns with both cultural awareness and data protection best practices.
As Eid 2025 approaches, organisations should reflect on whether they are demonstrating inclusivity without unnecessary data collection. Are you handling religious data responsibly, or is there more to consider? To ensure your organisation stays compliant while fostering an inclusive workplace, consult a Global Data Protection Officer (DPO). Submit a query today to assess your data practices and strengthen your approach to employee privacy.
Written by
Lynsey Hanson | Global Data Protection Officer