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

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