Article
International Data Transfers Guide - Data Protection Network
dpnetwork.org.uk
Quoted on this wiki
Every place a page here uses this source, in the order the words come in it.
This guide aims to give an overview of what international data transfers are and the key data protection considerations. It does not cover all the intricacies, nor data transfers for immigration and law enforcement purposes. Also please be aware there may be specific restrictions in place under laws in other territories around the world. “A processor will be responsible when they initiate the transfer, usually to a sub-processor.” Some might be thinking; what would be the impact if we just put all of this into the ‘too difficult’ tray? It’s certainly an area which many feel has become unduly complicated and an onerous paperwork exercise.
The rules regarding restricted transfers can be an enigma to the uninitiated and their complexity has been magnified by Brexit and by an infamous 2020 European Court ruling known as ‘Schrems II’. “Also please be aware there may be specific restrictions in place under laws in other territories around the world.” As a general rule, controllers based in the UK or EU are responsible for making sure suitable measures are in place for restricted transfers to other controllers, or to processors. A processor will be responsible when they initiate the transfer, usually to a sub-processor.
Some might be thinking; what would be the impact if we just put all of this into the ‘too difficult’ tray? It’s certainly an area which many feel has become unduly complicated and an onerous paperwork exercise. “It’s an area likely to come under regulatory scrutiny, in the event of a breach or should a complaint be raised.” What is an international data transfer?