External parties and transfers

Approve an international transfer

Identify the exporter, the importer, the countries, the data, the purposes and the mechanism, and hold the transfer inactive until the safeguard and its evidence are approved.

A support desk routed to an offshore team means personal data leaves the European Economic Area, and that movement needs its own record before it happens, not a retrospective justification once discovered.

This is exercised whenever an activity's systems or processors sit outside the Area: the transfer record captures both parties, both countries, the data involved and the mechanism relied upon, and stays inactive until that mechanism is evidenced.

The proof is that a transfer with no mechanism cannot go active, and that the record of processing states the destination and the safeguard for anyone reading it.

Regulation
Articles 44 to 49
Registers
Transfer record · Processing activity · Entity · Agreement
The transfer register.
The transfer register.

The steps

  1. 01Open the Transfer register and use the plus button beside the register title to create the transfer record.
  2. 02Name the exporter and the importer, and the country of each, on the Details tab.
  3. 03Choose the mechanism: adequacy decision, appropriate safeguard or derogation.
  4. 04Where a safeguard is relied upon, open the Evidence tab and attach the clauses and the assessment.
  5. 05Open the Linked records band and use "Link a record" to attach the processing activity the transfer supports.
  6. 06Move the transfer from Draft to Active on the lifecycle bar once the mechanism is evidenced.
Recording the exporter, the importer and the mechanism relied upon.
Recording the exporter, the importer and the mechanism relied upon.

Accepted when

  • A transfer with no mechanism cannot become active.
  • The record of processing states the destination and the safeguard.
The transfer held inactive until the mechanism is evidenced.
The transfer held inactive until the mechanism is evidenced.

Documents that carry the evidence

SCC · Standard contractual clauses pack
The Commission clauses with the annexes prepared for completion from the transfer record. Article 46(2)(c).
TIA · Transfer impact assessment
The assessment of the destination, the safeguard relied upon and the supplementary measures applied to a transfer. Articles 44 and 46.

These templates are issued when the register opens, so the document exists before the record that cites it.