Every Cloud Service, Every Overseas Processor, Every Cross-Border Email Is a Regulated Transfer. Is Yours Lawful?
Under UK GDPR Article 44, transferring personal data outside the UK without a valid legal basis isn't a technical oversight — it's a breach. Most FCA-regulated firms transfer data internationally every day through cloud platforms, outsourced services, and group company arrangements, often without realising it. Without a documented framework, you can't demonstrate compliance, defend a transfer decision, or respond to an ICO inquiry.
This ready-to-use International Data Transfer Policy gives FCA-regulated firms a comprehensive governance framework covering every aspect of cross-border data transfers — from adequacy decisions and IDTA implementation through to Transfer Risk Assessments, sub-processor management, incident response, and a quarterly self-assessment tool.
Customise with your firm name. Review your active transfers against it immediately.
What's included: UK GDPR Chapter 5 (Articles 44–50) compliance framework · Current adequacy decision register (EEA, Andorra, Japan, South Korea, US Data Privacy Framework, and more) · Monthly adequacy monitoring procedures · Approved transfer mechanisms (SCCs, IDTA, BCRs, certification) · IDTA implementation requirements · Transfer Risk Assessment (TRA) methodology and approval workflow · 23-working-day multi-stage TRA governance process · AES-256 encryption and SFTP/VPN secure transfer requirements · Special category data enhanced transfer controls · Transfer Compliance Committee structure · Departmental Transfer Coordinator responsibilities · Third-party and sub-processor due diligence and vetting · Contractual safeguards requirements · 2-hour incident notification trigger · ICO 72-hour breach notification procedures · Incident severity classification matrix · International Transfer Incident Response Team structure · Transfer register and documentation standards · Quarterly performance metrics and KPI dashboard · Comprehensive appendices: TRA form, transfer mechanisms checklist, self-assessment tool, emergency contacts
Built for: Data Protection Officers, compliance officers, IT security teams, and legal counsel at FCA-regulated firms with cloud-based operations, overseas processors, or group company structures.
Every Cloud Service, Every Overseas Processor, Every Cross-Border Email Is a Regulated Transfer. Is Yours Lawful?
Under UK GDPR Article 44, transferring personal data outside the UK without a valid legal basis isn't a technical oversight — it's a breach. Most FCA-regulated firms transfer data internationally every day through cloud platforms, outsourced services, and group company arrangements, often without realising it. Without a documented framework, you can't demonstrate compliance, defend a transfer decision, or respond to an ICO inquiry.
This ready-to-use International Data Transfer Policy gives FCA-regulated firms a comprehensive governance framework covering every aspect of cross-border data transfers — from adequacy decisions and IDTA implementation through to Transfer Risk Assessments, sub-processor management, incident response, and a quarterly self-assessment tool.
Customise with your firm name. Review your active transfers against it immediately.
What's included: UK GDPR Chapter 5 (Articles 44–50) compliance framework · Current adequacy decision register (EEA, Andorra, Japan, South Korea, US Data Privacy Framework, and more) · Monthly adequacy monitoring procedures · Approved transfer mechanisms (SCCs, IDTA, BCRs, certification) · IDTA implementation requirements · Transfer Risk Assessment (TRA) methodology and approval workflow · 23-working-day multi-stage TRA governance process · AES-256 encryption and SFTP/VPN secure transfer requirements · Special category data enhanced transfer controls · Transfer Compliance Committee structure · Departmental Transfer Coordinator responsibilities · Third-party and sub-processor due diligence and vetting · Contractual safeguards requirements · 2-hour incident notification trigger · ICO 72-hour breach notification procedures · Incident severity classification matrix · International Transfer Incident Response Team structure · Transfer register and documentation standards · Quarterly performance metrics and KPI dashboard · Comprehensive appendices: TRA form, transfer mechanisms checklist, self-assessment tool, emergency contacts
Built for: Data Protection Officers, compliance officers, IT security teams, and legal counsel at FCA-regulated firms with cloud-based operations, overseas processors, or group company structures.
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