International transfers

GDPR Chapter V, Articles 44 to 49: when a data flow is a transfer, adequacy decisions including the EU-US Data Privacy Framework, standard contractual clauses and supplementary measures, binding corporate rules, foreign authority requests and derogations.

Decision (EU) 2023/1795 EU-US Data Privacy Framework

The adequacy decision for US organizations that self-certify to the Data Privacy Framework: scope, the Commission's first review, the General Court judgment upholding it and the pending appeal, as of October 2026.

Article 46 Transfers subject to appropriate safeguards

The safeguards that allow transfers without an adequacy decision: Commission and authority clauses, binding corporate rules, codes of conduct, certification, and ad hoc clauses that need authorization, plus the requirement of enforceable rights.

Article 46(2)(c) Standard contractual clauses

The Commission's 2021 standard contractual clauses for transfers: the four modules, the Clause 14 assessment of local laws, handling public authority requests under Clause 15, and the technical measures annex.

Article 47 Binding corporate rules

Group-wide binding rules approved by a supervisory authority for intra-group transfers: approval through the consistency mechanism, required content including audits and training, and the EDPB controller and processor recommendations.

Article 49 Derogations for specific situations

Transfers without adequacy or safeguards in limited situations such as explicit consent, contract necessity and legal claims, the narrow compelling-legitimate-interests fallback, and why derogations cannot support regular transfers.

Talk to our team.

Tell us what you're working on, whether it's a deployment, an audit, a security test or a cyber range. You'll speak with an engineer who can help you scope it.

  • 30-minute call: free, with no obligation.
  • NDA on request: we can sign before you share details.
  • Clear next steps: a scope and plan after the call.