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A Guide to GDPR International Transfers - GRC Solutions
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“[The international transfer] is necessary for the purposes of compelling legitimate interests pursued by the controller which are not overridden by the interests or rights and freedoms of the data subject, and the controller has assessed all the circumstances surrounding the data transfer and has on the basis of that assessment provided suitable safeguards with regard to the protection of personal data”. “As is standard with legitimate interests, you must inform the data subject of that interest, as well the international transfer.” Unlike the lawful basis legitimate interests, there’s no assessment for this. However, you must keep records that show your decision-making process around what the legitimate interest was, why you deemed this the appropriate transfer method, that you’ve informed your data subjects, etc.