Mapping Third Country Transfers
How do you map your third country transfers? Why does it matter? What about the Trans-Atlantic Data Privacy Framework?
Publish date: December 9, 2024
Why do we need to map third country transfers
You are required to map third country transfers in order to ensure that you comply with the GDPR regulations regarding the transfer of personal data to countries outside of the EU/EEA.
This includes ensuring that adequate safeguards are in place to protect personal data when it is transferred to third countries.
The purpose of the mapping is to ensure that the rules of the regulation are not diluted because the information is transferred to countries outside the EU/EEA that are not subject to GDPR.
When you map your third country transfers to your vendors, this information will be included in your Records of Processing Activities (ROPA) report. In the report it will therefore be stated that you have documented your basis for third country transfer.
How do I map third country transfers
In Wired Relations you map your third country transfers from your vendors. Because you will always be transferring personal data to another independent legal entity.
To map your transfers open up one of your vendors, and go to the tab "Locations". From here you can map transfers that take place directly to this vendor, and also any transfers to sub-processors.
By adding a location you can type in the address, zip code, city, and most significantly the country that the transfer takes place to.
If you add a country outside of the EU/EEA then a 5th question will appear "Is personal data transferred to this location?"
If yes, then you need to select at least one legal mechanism for the transfer.
Mapping sub-processor transfers
Mapping your sub processors is very similar. The difference is that you're able to add additional information such as who the processor is and the purpose of the transfer.
Note the sub-processor function is limited to our paid plans.
The Trans-Atlantic Data Privacy Framework (transfer to companies in the United States)
With the new Trans-Atlantic Data Privacy Framework we now have a replacement for the Privacy Shield transfer mechanism. Remember that this is a certification framework, and can only be used as a transfer mechanism to certified companies. See the list of certified companies here.
If your site was created before July 10th 2023 then your list of legal transfer mechanisms will by default include Privacy Shield and not the Trans-Atlantic Data Privacy Framework.
To change this simply go to Settings -> Legal justification for transfer (see picture below)
From here you can add, delete, and rename the transfer mechanisms.