Transfer impact assessment (TIA) / transfer risk assessment (TRA)
We help businesses evaluate risks when transferring personal data across borders under GDPR, UAE PDPL, and other regulations. Our assessments identify legal, technical and security safeguards needed for compliant international data flows.
Key Benefits:
✔ Ensure lawful cross-border data transfers
✔ Assess third-country data protection risks
✔ Implement required safeguards and documentation
What is a transfer impact assessment?
A transfer impact assessment (TIA), sometimes called a transfer risk assessment (TRA), examines whether personal data sent to another country will still be adequately protected once it arrives. It looks at the destination country’s laws and practices, including government access to data, and at the safeguards you put in place, such as contracts and technical measures.
When you need one
- GDPR and UK GDPR: Chapter V restricts transfers outside the EU or UK. Following the Schrems II decision of the Court of Justice of the EU, organisations relying on Standard Contractual Clauses (or the UK equivalents) are expected to assess whether the destination country’s laws undermine those protections and add supplementary measures where needed.
- UAE PDPL: allows transfers abroad to countries considered to offer adequate protection, or to others where appropriate safeguards such as contracts or other conditions are in place.
- DIFC DPL and ADGM DPR: allow transfers to jurisdictions recognised as adequate, or under approved safeguards, and expect the risks to be assessed and recorded.
- Saudi PDPL: permits transfers outside the Kingdom only under conditions set by the law and its Implementing Regulations.
Typical examples include using a cloud provider whose servers are overseas, sharing data with a parent company or affiliate in another country, outsourcing support or payroll, and using software with international sub-processors. This page is general information, not legal advice.
What our transfer assessments cover
- Mapping which personal data goes where, to whom and why
- Identifying the legal mechanism relied on for each transfer, such as adequacy, contractual clauses or another permitted route
- Assessing the destination country’s laws and practices, including public authority access to data
- Reviewing technical safeguards such as encryption, key control, pseudonymisation and access restrictions
- Reviewing contracts and data protection agreements with vendors and affiliates
- Recommending supplementary measures where the risk is too high
- Documenting the conclusion so you can show it to a regulator or customer
How we run a transfer assessment
- Inventory the transfers: we list each cross-border flow and its purpose.
- Pick the mechanism: we confirm the legal basis for each transfer under every applicable law.
- Assess the risk: we analyse the destination’s legal environment and your safeguards.
- Recommend: we propose contractual and technical measures, or alternatives such as keeping data local.
- Record and review: we document the result and set a schedule to revisit it.
Frequently asked questions
Is a TIA the same as a DPIA?
No. A DPIA assesses the risks of a project to individuals. A TIA focuses on the specific risks of moving data to another country. A single project can need both.
Do we need a TIA for every transfer?
Not necessarily for each one separately. Comparable transfers can often be assessed together, and some transfers rely on adequacy decisions. We help you decide the right level of detail.
Does using a global cloud provider count as a transfer?
It can, depending on where the data is stored and accessed from, including by support staff and sub-processors. We review the provider’s setup and contract terms.
What if the assessment finds the risk too high?
Options include supplementary technical measures, changing the vendor or data location, limiting what is sent, or stopping the transfer. We help you weigh them.
Which laws should we map?
That depends on where your data subjects and entities are located. See our UAE and regional compliance service and EU and UK GDPR service.