Yes — personal data printed on the card or stored against the cardholder record (name, photo, Emirates ID number, department) is personal data under UAE Federal Decree-Law No. 45 of 2021 (PDPL). If your credential carries a biometric template, that template is sensitive personal data and additional safeguards apply, with on-device or template-on-card storage strongly preferred. The customer remains the data controller and is responsible for lawful basis, consent where required, and the cardholder data-retention policy. We configure the access platform to support those controls.