Case study: Cross-border data transfer compliance

This is an illustrative (representative) scenario about transferring personal data abroad; it does not represent a real customer.

This content is for general information only and does not constitute legal advice.

Situation

A technology company used cloud services with servers abroad for CRM, email and analytics. It had not realized data was being transferred abroad; there was no transfer mechanism or notification to the Board.

Risks

• Cross-border data flows with no inventory.
• No appropriate transfer mechanism chosen (adequacy decision / safeguard / exception).
• The standard contract not notified to the Board.
• Non-compliance with the Article 9 amendment effective 1 June 2024.

Measures applied

1. Transfer inventory: All cross-border data flows and recipients were mapped.
2. Mechanism selection: An appropriate safeguard or exception was assessed per flow.
3. Standard contract: Standard contracts were signed for the relevant transfers.
4. Board notification: The standard contracts were notified within the statutory period.

Result

By applying administrative (inventory, contracts) and technical (access, logging) measures together, a 2024-compliant, traceable cross-border transfer structure was set up.