As the regulatory landscape in the Middle East tightens, safeguarding sensitive information has never been more important for organisations running SAP systems. With updated data protection laws, such as the Personal Data Protection Law (PDPL) in the Kingdom of Saudi Arabia (KSA) coming into force, businesses need to look at taking proactive steps to avoid penalties, reputational harm and the potential of data breaches. One solution to protecting sensitive data within an SAP landscape is data scrambling. But what exactly does it mean, why does it matter so much, and how can EPI-USE Labs help? We spoke to Rohin Ramjee, Regional Architect - Europe, Africa and the Middle-East at EPI-USE Labs, to break it down for us.
As the regulatory landscape in the Middle East tightens, safeguarding sensitive information has never been more important for organisations running SAP systems. With updated data protection laws – such as the Personal Data Protection Law (PDPL) in the Kingdom of Saudi Arabia (KSA) – coming into force, businesses need to look at taking proactive steps to avoid penalties, reputational harm and the potential of data breaches.
One solution to protecting sensitive data within an SAP landscape is data scrambling. But what exactly does it mean? Why does it matter so much, and how can EPI-USE Labs help? We spoke to Rohin Ramjee, Regional Architect - Europe, Africa and the Middle-East at EPI-USE Labs, to break it down for us. Having implemented data privacy solutions across many diverse systems and landscapes for our clients, Rohin is a subject matter expert concerning data privacy, security and risk.
“This refers to the randomising or modifying of data that can identify an individual. This can be with random values or constant values, and the goal is to not have any visible Personally Identifiable Information (PII) in a non-production SAP environment.”
In other words, when businesses copy data from Production systems to non-production systems for testing or training, the personal data remains intact unless steps are taken to anonymise it. Without scrambling, developers, testers and third parties could have unnecessary access to this sensitive information.
Scrambling replaces this real personal data, such as salary information and addresses, with realistic but fictitious values, preserving system functionality while ensuring compliance and security.
“Organisations in the Middle East are implementing frameworks of the UAE Personal Data Protection Law and Saudi Arabia's amended personal data protection laws. These laws put obligations on data controllers and processors to comply.”
This means that any company handling personal data – whether of employees, customers or vendors– must protect it across all environments, not just in Production. Non-production environments are often less secure but contain full copies of live data, making them a target for cyberattacks or insider threats.
The importance is amplified by SAP RISE contracts, which explicitly require scrambling of data in non-production systems. This requirement exists because privacy laws like GDPR, POPIA, and PDPL set strict guidelines for how personal data should be handled across the entire landscape.
Many businesses focus on scrambling as a compliance checkbox. But Rohin warns that the stakes are, in actual fact, far higher:
“Besides compliance reasons, it's a necessary step to protect against external data breaches. External data breaches can have large impacts on organisations, not only from a legal compliance issue, but reputational and financial damages.”
Consider what happens when a non-production system is breached. Attackers often target these environments because they typically have weaker security controls, more users with access, and third-party contractors logging in. Once breached, the exposed personal data can lead to lawsuits, fines and additional fraud.
Scrambling renders that stolen data useless.
“In the event of a data breach where the organisation has scrambled data in their non-production SAP system, the impact is less severe, as the data cannot be related back to an actual individual.”
Failing to scramble data doesn’t just expose companies to regulatory penalties:
“Failure to comply with the requirements can lead to significant consequences. One is compliance breaches. You also have increased security vulnerabilities because non-production systems have many more people or external people that tend to log in and have access to that information. So the chance of human error or the leak of data is much larger. There are also project delays because of data breaches, potential fines from regulatory bodies and reputational damage.”
Rohin adds that compromised data can fuel identity theft, financial crimes, and CEO fraud, where hackers impersonate executives to trick employees into transferring funds. The ripple effect of a single data breach can cost millions – both financially and a loss in trust.
EPI-USE Labs has been mapping SAP’s data model for over 25 years, giving us a unique advantage in delivering consistent, effective scrambling.
“All data within SAP systems is connected. This has given us that competitive advantage as our solution can ensure consistent scrambling across all related data within SAP.”
For example:
And it doesn’t stop at a single system:
“If you need to scramble a customer in an ECC system or S/4HANA environment, we can trigger the scrambling run in a SAP CRM system too. This ensures data integrity across landscapes.”
This cross-system capability is crucial for businesses running multiple SAP and non-SAP systems. It keeps testing consistent and ensures a global scrambling policy across the landscape.
One common concern is whether scrambling will break processes or make testing unreliable:
“We can surgically alter the PII data and retain the functional integrity of the data, thus giving an organisation the best of both worlds: protected data and the ability to do testing on Production-like data.”
This means that even after scrambling, businesses can still run meaningful tests, training sessions, and upgrades without disruption.
As detailed in our blog, RISE with SAP Data Refreshes and DPA Compliance, scrambling isn’t optional – it’s mandatory for RISE clients. SAP contracts specify this to align with global privacy standards and protect customer data during cloud migrations.
Rohin’s top piece of advice:
“Start by understanding your risks. Identify where your PII exists within your system and take the necessary precautions to protect your data to prevent becoming a statistic.”
Q1: What’s the difference between scrambling and masking?
Scrambling replaces PII with random values at the database level, making it irreversible. Masking (also known as UI data protection masking for SAP) only hides data for display and can be bypassed.
Q2: Can we still test after scrambling?
Yes. Our solution keeps data integrity intact, so tests remain accurate and business processes function as expected.
Q3: Is scrambling required under UAE PDPL and Saudi PDPL?
Yes. Both laws require that personal data be protected in all environments, not just Production.
Q4: Can we scramble custom fields?
Absolutely. EPI-USE Labs supports custom objects, Z-tables, and industry-specific configurations.
Q5: Why not use dummy data?
Dummy data is costly to create and often unrealistic. Scrambling retains real data complexity while anonymising sensitive details.