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TRANSFERS · TIA GUIDEGDPR transfer impact assessment.
GDPR transfer impact assessment.
Document the decision.
Signing contractual clauses does not automatically complete the assessment. Organisations need to understand the transfer, mechanism, third-country context, possible access and effectiveness of supplementary measures.
A Transfer Impact Assessment, or TIA, documents a third-country transfer: actors, personal data, purposes, frequency, transfer mechanism, relevant law and practices, technical and organisational measures, residual risk, decision and reassessment.
Residual risk
Downloadable checklist
Describe the transfer
Actors
Identify exporter, importer, subprocessors and teams with access.
Data
Document categories, volume, sensitivity, individuals, purpose and frequency.
Architecture
Map storage, transit, support, administration, backups and emergency access.
Assess the mechanism and context
Mechanism
Identify adequacy, Standard Contractual Clauses, binding corporate rules or an exceptional derogation.
Third country
Assess relevant law and practices concerning public-authority access in the context of the specific transfer.
Documented experience
Use factual, transparent and verifiable information from the importer carefully and in context.
Measures and decision
Technical measures
Assess encryption, pseudonymisation, key separation and data minimisation for the use case.
Contractual and organisational measures
Consider notification, challenge, transparency, access procedures and permission controls.
Conclusion
Record the decision, residual risk, conditions, owner, approval date and review trigger.
IMPLEMENTATION GUIDE
Move from checklist to a documented decision
Start with the actual transfer, not a template
A TIA should identify the exporter, importer, purpose, personal data and every party able to access it. Include subprocessors, support, administration, backups and emergency access. A country or vendor name alone does not describe the practical exposure that the assessment must address.
Distinguish storage, transit and remote access. Record frequency, duration, volume, sensitivity, re-identification potential and who controls the keys. This mapping supports selection of the relevant contractual module and measures designed for the actual use case rather than generic safeguards.
Assess context and measures with traceable evidence
The assessment considers whether relevant law and practices in the third country may affect the mechanism in the context of this transfer. Information should be reliable, verifiable, current and connected to the data and access concerned. The importer’s documented experience can inform the analysis but should not replace an independent and reasoned assessment.
Supplementary measures may be technical, contractual and organisational. Effectiveness is contextual: encryption offers different protection where the importer holds the keys and must process data in clear text. Record assumptions, limitations and the facts that would require the conclusion to change.
Decide, approve and reassess
The conclusion states whether the transfer may begin or continue, under which conditions and with what residual risk. Name the decision owner, action owners, deadlines and expected evidence. Where safeguards cannot provide the required protection, the transfer may need to be suspended, redesigned or replaced following competent assessment.
Set reassessment triggers such as a change of country, provider, subprocessor, architecture, data category, purpose or applicable law. For flows involving Morocco, a GDPR TIA does not replace the separate assessment of transfer formalities under Law 09-08 and CNDP procedures.
PDF · PRACTICAL RESOURCE
Get the PDF version
Receive a preparation template before the legal and technical assessment.
FAQ
Frequently asked questions
Is a TIA always required?+
It is particularly relevant where a transfer relies on safeguards such as Standard Contractual Clauses and must be adapted to context.
Does a TIA replace the SCCs?+
No. It assesses whether the mechanism and measures provide essentially equivalent protection.
Can remote support access be a transfer?+
Yes. Access from a third country may be a transfer even where hosting remains in the EEA.
Does a GDPR TIA cover CNDP formalities?+
No. Moroccan Law 09-08 requirements must be assessed separately where applicable.
When should a TIA be reviewed?+
After changes to the vendor, country, architecture, data, applicable law or facts affecting the conclusion.
This guide provides a general framework and does not replace an assessment of your circumstances or reserved legal advice.
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