Efficient DTIA implementation: Control your risks
After Schrems II, a DTIA is often necessary. We help organizations implement legally robust DTIAs and accelerate the process with our specialized DTIA database (“Atlas”).
A DTIA is not a paper compliance exercise
Today, you can be compliant. Tomorrow, your risk profile may change completely. Through new legislation. Due to geopolitical developments. Or simply because your supplier is being taken over.
International data transfers are not just about privacy — it's about control, jurisdiction, and actual control over your data.
What organizations run into:
- Schrems II obligations: When transferring based on SCCs, a substantiated, case-by-case DTIA is necessary.
- SCCs alone are no guarantee: additional technical and organisational measures are often required.
- Uncertainty about data sovereignty: who ultimately has access to your data and under what legislation?
- Ownership can change: even “local” suppliers may fall under foreign control during the contract period.
- Complex and time-consuming process: country research, data flows and legal substantiation require specialist expertise.
The recent Solvinity case shows how quickly concerns arise about access by foreign governments and dependence on vital digital infrastructure.
It is not enough to be compliant. You must demonstrably remain in control.
DTIA-as-a-Service
✔ What does it bring
DTIA-as-a-Service ensures that you:
- Understand your international data flows and risks (e.g. access by foreign authorities, supervision by local laws, or limited legal protection)
- Choose measures that suit your processing (substantiated on the basis of risk analysis and legal assessment)
- Demonstrably in control: decision logic, risk acceptance and audit-proof documentation
- Continuously controls changes (supplier, sub-processors, countries, legislation) through clear governance and periodic reassessment
- Control over privacy risks during international transfers (including clear responsibilities, reassessment moments and a defensible file)
Outsourcing DTIA
Assurance about international data transfers: legally substantiated and audit-proof.
Do you work with cloud software, support teams outside Europe, or suppliers with sub-processors in the US, India, or the UK? Then there is a good chance that there is an international data transfer under the GDPR. And then you must be able to demonstrate that the level of protection remains equivalent to that within the EU.
A Data Transfer Impact Assessment (DTIA) is the basis for determining:
- Whether your international transfer is allowed
- Whether SCCs or other safeguards offer sufficient protection in practice
- What additional technical and organizational measures are necessary
We combine our in-depth knowledge and experience of privacy legislation and international transfers to ensure that DTIAs are carried out carefully and efficiently within your organization.
Global Data Transfer Atlas
What is Atlas?
The Global Data Transfer Atlas (“Atlas”) helps you make data sovereignty practical: you get a reusable legislative analysis for each country outside the EEA (“third country”) that you can use directly in your DTIA and stays up to date. As an organization, this prevents the same country survey from having to be carried out internally several times.
More efficient DTIAs with our Atlas
Thanks to pre-developed legislative analyses, we do not have to re-investigate foreign legislation before every data transfer. As a result, we implement DTIAs faster and more cost-effectively than a fully internal approach.
What can Atlas achieve for you?
More data sovereignty in practice
Consistent substantiation of jurisdictional and entry risks by country, as a permanent building block in your DTIA
Faster reassessment in the event of changes
If legislation or supervisory developments change, you can determine more quickly whether your measures are still appropriate
Chain control and continued control of privacy risks
One central source for country analyses supports consistent agreements with suppliers and (sub) processors
What is the purpose of Atlas?
Atlas realizes that your organization remains demonstrably in control of risks during international transfers, partly due to the following results:
- Comply with accountability and thus increasing your compliance;
- Central assurance of country analyses;
- Increasing consistency and audit resilience;
- Reduction of implementation costs;
- Structural control over risks;
- Rapid reassessment in the event of legislative changes or changes in ownership.
DTIA-as-a-Service & Atlas
With DTIA-as-a-Service and the Global Data Transfer Atlas, you can control your privacy risks and data sovereignty — from country analysis to defensible documentation and appropriate safeguards.
Working method
Our approach is directly in line with the reality that ownership relationships can change during contracts and that this can introduce new risks.
Intake & scope
We map the processing activities, data flows, parties involved and ownership structure and determine the scope of the DTIA. In doing so, we directly test for data sovereignty and possible extraterritorial legislation.
Country & Risk Analysis
We analyse the third country's legal framework and the actual processing (nature of data, sensitivity, access, scale) and assess whether an essentially equivalent level of protection exists. The outcome is recorded in a substantiated risk analysis.
Additional Safeguards
If necessary, we recommend targeted technical, organizational and contractual measures to mitigate identified risks, including safeguards for change of control situations
Delivery & Review
We provide a structured, audit-proof DTIA report with clear conclusions and recommendations. In addition, we provide periodic or trigger-based reassessment for relevant changes, such as changes in ownership or legislative developments.
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