International Data Transfer Risk Assessment

Decide whether a restricted transfer is lawful – adequacy, IDTA or UK Addendum, or an exception – and record the new “data protection test” introduced by the Data (Use and Access) Act 2025.

Editable Word document
9
10pages
Guidance notes included
aml consultancy solutions

Data protection & GDPR

International Data Transfer Risk Assessment

About this document

What it’s for

A transfer risk assessment for sending or making personal data available outside the UK. It helps you identify whether a transfer is restricted, choose the right transfer mechanism, and – where you rely on appropriate safeguards such as the International Data Transfer Agreement (IDTA) or the UK Addendum – document that the “data protection test” is met: that the standard of protection after transfer will not be materially lower than in the UK.

When to use it

  • Before using a cloud, software, AI or support provider based outside the UK, or whose staff access data from abroad
  • Before sharing data with an overseas group company, partner or client
  • When a processor proposes a non-UK sub-processor

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  • Part 1 – Is this a restricted transfer?
  • Part 2 – Transfer details
  • 3A UK adequacy regulations
  • 3B Appropriate safeguards (Article 46)
  • 3C Exceptions (Article 49) – only if neither adequacy nor safeguards are available
  • Part 4 – The data protection test (appropriate safeguards only)
  • 4A Risk level of the data
  • 4B Destination – law and practice
  • 4C Importer and safeguard
  • Part 5 – Additional protective measures

How to complete it

  • Complete Part 1 to confirm a restricted transfer is involved
  • Record the transfer details in Part 2 and check adequacy first in Part 3
  • If relying on the IDTA or Addendum, complete Parts 4 and 5
  • Sign off in Part 6 and review annually or when anything changes

Key points to check

  • The list of UK adequacy regulations in Appendix 1 changes – check it is current
  • The regulator planned updated versions of the IDTA and Addendum in 2026 – check which versions to use
  • Exceptions in Part 3C are for occasional transfers only

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Data protection & GDPR

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Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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