Cross-Border Data Transfer: SCCs, Adequacy Decisions, Transfer Impact Assessments, and Technical Safeguards

Cross-Border Data Transfer#

Moving personal data across national borders is routine in distributed systems — a European user’s request hits a CDN edge in Frankfurt, the application runs in us-east-1, logs ship to a monitoring SaaS in the US, and backups replicate to ap-southeast-1. Each of these data movements is a cross-border transfer that may require legal justification and technical safeguards.

GDPR is the most impactful framework for cross-border transfers, but similar requirements exist in Brazil (LGPD), Canada (PIPEDA), South Korea (PIPA), Japan (APPI), and others. This guide focuses on GDPR as the reference model because most other frameworks follow similar principles.