10. Is express consent from customers or other data subjects required before moving data to the cloud?
No, it is not required expressly under the Dubai International Financial Centre ("DIFC") Data Protection Law (DIFC Law No. 5 of 2020, as amended by DIFC Law No. 2 of 2022) ("DPL"). Consent is an option. The DPL provides alternative grounds to rely on to legitimize transfers (e.g., legitimate interests).