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ASIRI

Cross-border transfers and processors

Track processors, sub-processors, countries, transfer mechanisms, SCCs, adequacy decisions, and supplementary measures.

Plain English

What the chapter means in practice.

Vendor residency changes create risk

A transfer register must stay connected to vendor reviews, DPAs, SCCs, cloud regions, and product architecture.

Operational takeaway

Teams need a transfer workflow that changes when vendors, countries, purposes, or data categories change.

Checklist

What to document.

  • List every processor and sub-processor by country and purpose.
  • Attach transfer mechanism and DPA evidence.
  • Review changes when vendors add regions or subprocessors.
Related workflows

Turn the chapter into an operating workflow.