Happy New Year? A look at the ICO's new 'international data transfers' guidance

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Rob looks at the ICO’s newly released guidance on international transfers and what it means for UK privacy professionals.

• The “Three-Step Test” for identifying restricted transfers

• Why UK processors returning data to overseas controllers are no longer “initiating” transfers

• Clarifications on transfers between branches and employees within the same legal entity

• How the guidance incorporates the Data (Use and Access) Act while retaining “TRA” terminology

• The distinction between legal entities and server locations in cloud service contracts

The skinny

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