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Transfer Impact Assessment

The Standard Contractual Clauses (SCCs), published by the European Commission in June 2021, specify in Clause 14 that a Transfer Impact Assessment (TIA) must be conducted before any data transfer to ensure a safe data flow. However, the obligation to perform a TIA applies to all data transfers to third countries, regardless of whether they are based on SCCs, Binding Corporate Rules (BCRs), or an adequacy decision. CYRVANA assists customers to complete that assessment.

Overview

Transfer Impact Assessment

Transfer Impact Assessment (TIA)

What Does TIA Entail?

TIA typically comprises of the following steps:

  • Overview of the intended data transfer
  • Definition of TIA parameters
  • Details of implemented safeguards
  • Risk assessment of unlawful access to the transferred personal data
  • Conclusion on whether the transfer meets an acceptable level of risk

When Is A TIA Needed?

TIA is required in various junctures of privacy journey.

  • Mandatory under EDPB Guidance
  • Data Transfers to Third Countries
  • Use of Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules (BCRs)
  • Schrems II Compliance
  • Introduction of New Data Processing Activities
  • Customer or Regulatory Inquiries

Service Highlights

Key features of our TIA service to enhance your organization's privacy posture. CYRVANA can assist by:

  • Identify and assess the compliance of in-scope transfers of EU residents’ data with the Schrems II ruling and relevant requirements under the EU and UK GDPR.
  • Facilitate the prioritization and planning of remediation efforts for any identified non-compliance.
  • Provide guidance on supplementary measures to implement for specific types of data transfers.
  • Support clients in responding to customer inquiries regarding EU data transfer compliance following the Schrems II ruling.

Benefits

At Cyrvana, we are committed to delivering unparalleled cybersecurity solutions tailored to meet your unique needs. Here’s why we stand out from the rest.

Ensure GDPR and Privacy compliance

In addition to ensuring privacy compliance and mitigating risks associated with data transfers before the transfer or processing begins, it also demonstrates your commitment to data protection.

Avoid Potential Fines and Judgements

TIA saves time, cost, and resources in potential fines, legal fees, and other related cost.

Enable Audit Readiness

This process provides a documented basis for the chosen transfer mechanism which will better prepare for any privacy audits.

Action Plan To Mitigate Transfer Related Risks

An outcome of this assessment is to prioritize next steps based upon legal requirements, EU guidance, and customer's local risk.

Reusable Risk Construct For Future Data Transfers

The assessment helps in building a reusable risk-based model of data transferred to existing and future suppliers.

Our Methodology

What's Involved

Feel free to reach out to us and discuss your needs. We align with EDPB's guidelines for a TIA.

Schedule Your Consultation

Schedule an initial consultation with our experts to discuss your organization's unique challenges and goals around the data transfer use case.

Define Scope

Before conducting the impact assessment, it is important to understand the scope of the transfer. This includes categories of personal data and any legal obligations that may apply. It is important to consult with internal teams and personnel during this process to understand additional privacy concerns.

Understand Transfers and Mechanisms

This phase involved understading more about what data you would like to transfer, where you transfer it, and the reason for tranfer. This step also involves understanding the mechanisms leveraged for the transfer, such as - Standard Contractual Clauses (SCCs), transfer derogations, etc.

Impact Assessment

The impact assessment will evaluate jurisdictional concerns and ensure that safeguarding measures are established before transferring personal data. This assessment will determine whether the transfer mechanism is effective by accounting for all scenarios that may apply. These may include - specific circumstances of the transfer, identifying relevant third-country laws, or problematic laws.

Develop a plan

Once the assessment is completed, if the impact assessment identifies any gaps, it is crucial to develop a plan to address them. This may involve protecting the exported personal data via supplementary measures.

Monitor and Review

Finally, it is crucial to continuously monitor and review the impact of the transfer. The transfer should be re-evaluated at appropriate intervals.

Ready To Initiate A Transfer Impact Assessment?

Don’t wait for a privacy incident to ensue. Protect your business with CYRVANA’s privacy solutions.
Commonly Asked Questions

FAQ

Find answers to common questions about our TIA service.

A TIA is required when personal data is transferred to a non-EU/EEA country without an adequacy decision, when using Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs), and in response to the Schrems II ruling. It may also be needed when introducing new data processing activities or addressing customer or regulatory inquiries about cross-border data transfers.

Supplementary measures are additional safeguards that organizations may need to implement when the destination country’s legal framework does not provide adequate protection for personal data. These measures can include technical, contractual, or organizational controls to enhance the security of the transferred data.

The data controller is responsible for ensuring that a TIA is conducted before transferring personal data to a third country. However, data processors may also be involved in providing necessary information and implementing supplementary measures.

Yes, a TIA can cover multiple data transfers if they involve similar types of data and are subject to the same risks and safeguards. However, each transfer should be assessed individually to ensure the TIA remains relevant and accurate.

Failing to conduct a TIA can result in non-compliance with GDPR, leading to potential fines, legal action, and damage to the organization's reputation. It also increases the risk of unauthorized access to personal data in the destination country.
Our Differentiators

Our Differentiators

Expert Leadership in Cyber and Privacy

With years of experience in cybersecurity and privacy, our team of experts brings unparalleled leadership and strategic insight. In our role as your business and technical advisors, we translate cybersecurity into your business language and aligning it with your business strategy. Our team comprises of experienced and seasoned Cyber leaders who are multi-skilled across security & privacy strategy, operations, threat research, technology operations, and program management.

Thought Leaders In Cyber and Privacy

Our thought leadership in cybersecurity and privacy helped us to grow as a trusted advisor, guiding organizations through complex digital landscapes. We actively seek to optimize customers' existing investments in security tools and solutions and augment those resources with our expertise, framework and processes that are contextualized to that specific customer. We offer insights that go beyond conventional solutions by staying ahead of emerging threats, regulatory changes, and technological advancements. This expertise has enabled us to craft proactive strategies that enhance security and privacy postures of our customer and foster trust in their digital ecosystems.

Our Value Proposition

Value Proposition

All our services are designed with customer obsession in mind with strong emphasis in bringing value to your business.

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Speed to Maturity

Ability to move your privacy program up the maturity curve rapidly with proven methodologies, technology & processes, and people powered by CYRVANA.

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White-glove Operating Model

CYRVANA's privacy capability along with delivery excellence to orchestrate privacy program while working closely with customer’s teams ensures the desired outcome for the customer.

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Dedicated Subject Matter Expert

A dedicated technical SME will be assigned ensuring timely management of privacy program issues and needs.

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Fit For Purpose

Move away from one-size-fits-all model to a bespoke model with standardization at core with flexibility at edge. This is paramount as we work together to build the privacy program.

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Sector Specific Context

CYRVANA's depth of expertise in various sector and industry specific threat use cases are key to achieve effective outcomes in cyber defense. We leverage and share experience of delivering such services with other customers in the same sector.

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Ecosystem Partnerships

CYRVANA leverages it's alliances and ecosystem partners when deemed fit to solve customer challenges. Alliance and ecosystem partners are cornerstone of CYRVANA's solutions and competency.

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Years of Industry Experience Between Leaders

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Business Value Generated

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Partnerships and alliances to deliver cyber and privacy services.

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Professional Certifications Attained and Maintained Between Consultants
Business Metrics

CYRVANA Outlook

Below are some metrics that enable us to help our customer's achieve their business goals.

11+ Years: Track record ensuring deep knowledge and insight.
25+ Successful Projects: Demonstrating our ability to implement effective solutions.
15+ Industry Certifications: Showcasing our commitment to continuous learning and excellence in cybersecurity.
Related Services

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Our Success Stories

Real Results, Real Impact

Discover how CYRVANA has helped businesses across industries enhance their cybersecurity, achieve compliance, and navigate digital transformation. Our case studies showcase tangible results and the powerful impact of our tailored solutions.

Securing a Growing E-commerce Platform

An emerging e-commerce platform faced increasing cyber threats as they scaled. With customer trust at stake, they needed a comprehensive solution to protect sensitive data and prevent breaches. CYRVANA implemented a full-spectrum cybersecurity plan, including risk assessments, data encryption, and ongoing vulnerability scans. With these protections in place, the platform was able to continue growing confidently, knowing their customer data and financial transactions were secure, ensuring a safer online shopping experience for their users.

Learnmore

Enabling Compliance for a Healthcare Provider

A healthcare provider was struggling to meet the strict requirements of HIPAA and ensure the safety of patient information. CYRVANA’s team developed a customized compliance roadmap, which included secure access management, encryption, and regular audits. By integrating these security measures, the healthcare provider not only achieved full compliance with HIPAA regulations but also enhanced the overall security posture of their systems, leading to improved patient trust and safety. CYRVANA’s proactive approach ensured that the healthcare provider remained audit-ready at all times.

Learnmore

Enhancing Cyber Resilience for a Financial Institution

A financial institution needed a strong defense system to mitigate the growing risks of cyber-attacks and ensure continuity of operations. CYRVANA designed a comprehensive cybersecurity framework, including advanced threat detection systems, a detailed incident response strategy, and a disaster recovery plan. This approach enabled the institution to minimize disruptions and reduce the potential impact of cyber threats. By strengthening their cybersecurity posture, the institution significantly boosted their resilience against attacks, allowing them to maintain business operations without compromising customer trust.

Learnmore
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Featured Insights

Section 500.04 of the New York state regulation 23 NYCRR 500 mandates companies with over 10 employees, $5 million in gross annual revenue, and $10 million in year-end total assets must designate a qualified individual to oversee Cybersecurity. In 2019, the state of South Carolina passed the South Carolina Insurance Data Security Act which specifically requires a designation responsible for the information security program. These are just a few and there are more that mandate an in-house CISO or a shared CISO. It’s no longer an option NOT to have a cybersecurity leader to orchestrate a cybersecurity program that will protect your critical assets and manage risk. There are no exceptions. Even if you are a small medium enterprise or even a start-up in a basement there are ways you can engage us to address your cybersecurity needs before it’s too late.

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