Map an organisation's cross-border data flows to identify which transfers require a legal transfer mechanism.
International Data Transfers Using Standard Contractual Clauses and Transfer Impact Assessments
Trains privacy and legal teams to implement standard contractual clauses, run transfer impact assessments and select supplementary measures for cross-border data transfers.
Course Overview
Moving personal data across a border no longer ends with signing a standard contractual clause: the exporting organisation must also assess whether the destination country's laws, particularly its government access powers, undermine the protection those clauses promise on paper. This course starts by mapping cross-border data flows across vendors, group entities and cloud infrastructure to find every restricted transfer, then works through the modular structure of standard contractual clauses so participants select the right module for controller-to-controller, controller-to-processor or processor-to-processor relationships. Participants build a transfer impact assessment that researches destination country law, documents its methodology and identifies supplementary measures, such as encryption, pseudonymisation and contractual notification obligations, that address residual risk. The course compares clauses against adequacy decisions, binding corporate rules and narrow derogations, and closes with the transfer register and review cadence that keeps documentation ready for a supervisory authority request.
Expected Learning Outcomes
Select the correct modular standard contractual clause set for a given controller and processor relationship.
Conduct a transfer impact assessment evaluating the destination country's law and government access powers.
Identify supplementary measures, including encryption and pseudonymisation, that address an identified transfer risk.
Draft onward transfer provisions that maintain protection when data moves beyond the first recipient.
Compare standard contractual clauses with adequacy decisions, binding corporate rules and derogations.
Maintain a transfer documentation file that evidences compliance to a supervisory authority on request.
Who Should Attend
Data protection officers managing cross-border transfer compliance programmes
In-house privacy counsel negotiating vendor and intra-group data transfer terms
Procurement teams onboarding vendors that process data outside the home jurisdiction
IT security leads assessing technical measures for international data flows
Group compliance managers coordinating intra-group data transfer agreements
External counsel advising on multinational data transfer risk assessments
Course Modules
Select any module to see its sessions and points.
01Mapping Transfers and Choosing a Mechanism
2 sessions · 8 points
Session 1Identifying Restricted Transfers
- Map data flows across vendors, group entities and cloud infrastructure to locate cross-border transfers.
- Determine when remote access from a third country counts as a restricted transfer requiring a safeguard.
- Distinguish transfers to countries with an adequacy decision from transfers requiring additional safeguards.
- Inventory categories of personal data and data subjects involved in each identified transfer.
Session 2Comparing Available Transfer Mechanisms
- Compare standard contractual clauses with binding corporate rules for intra-group transfer programmes.
- Assess when a derogation, such as explicit consent or necessity for contract performance, may apply.
- Evaluate the administrative burden and timeline of implementing binding corporate rules versus clauses.
- Select the mechanism proportionate to the transfer volume, sensitivity and business relationship.
02Implementing Standard Contractual Clauses
2 sessions · 8 points
Session 1Modular Structure and Drafting Choices
- Select the correct module for controller-to-controller, controller-to-processor or processor-to-processor transfers.
- Complete the annexes describing data categories, processing purposes and technical and organisational measures.
- Draft onward transfer provisions that bind sub-processors to equivalent contractual protections.
- Align docking clauses and multi-party signature mechanics for group-wide clause implementation.
Session 2Integrating Clauses into Commercial Contracts
- Incorporate standard contractual clauses into master service agreements without creating clause conflicts.
- Negotiate liability and indemnity provisions that interact correctly with the clauses' own liability regime.
- Coordinate clause execution timing with vendor onboarding and data processing agreement sign-off.
- Track clause versions across the vendor estate to ensure superseded versions are replaced promptly.
03Conducting the Transfer Impact Assessment
2 sessions · 8 points
Session 1Assessing Destination Country Law
- Research the destination country's surveillance and government access laws relevant to the data transferred.
- Assess whether local law provides data subjects with a practical and enforceable remedy against access.
- Document the assessment methodology and sources consulted for a defensible transfer impact assessment.
- Reassess a transfer impact assessment when the destination country's legal or political circumstances change.
Session 2Selecting and Documenting Supplementary Measures
- Select technical measures, including encryption in transit and at rest, appropriate to the identified risk.
- Apply pseudonymisation or data minimisation to reduce the volume or sensitivity of transferred data.
- Add contractual supplementary measures, such as government access notification and challenge obligations.
- Record the combination of measures adopted and the residual risk accepted by the business owner.
04Governance, Monitoring and Regulatory Engagement
2 sessions · 8 points
Session 1Documentation and Ongoing Compliance
- Build a transfer register linking each transfer to its mechanism, impact assessment and supplementary measures.
- Set a review cycle that reassesses transfers following vendor changes or new sub-processor appointments.
- Coordinate transfer documentation with the records of processing activities required under data protection law.
- Train procurement and business teams to flag new cross-border arrangements before data starts flowing.
Session 2Responding to Regulators and Data Subject Challenges
- Prepare a response to a supervisory authority request for evidence of transfer compliance.
- Assess the impact of a regulatory decision invalidating a transfer mechanism on existing contracts.
- Advise on suspending or migrating a transfer where a mechanism is successfully challenged.
- Update the transfer compliance programme following supervisory authority guidance or enforcement trends.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
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