ISO Compliance Insights & Best Practices
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ISO Compliance Insights & Best Practices
TIA review and monitoring is the step that separates a living transfer assessment from a document that was accurate on the day it was signed. Transfers to third countries depend on the law and practice of the destination, on the tool you rely on and on the supplier’s set-up, and all three change. The EDPB recommends that exporters monitor developments in the third country on an ongoing basis and re-evaluate when needed.
This guide explains what triggers a review, how often to schedule one, what to check, who should own the process and how to record decisions. It is general information, not legal advice, and you should confirm the approach with your DPO or counsel.
A transfer impact assessment records a conclusion at one moment. The world does not stand still: laws are passed, courts issue judgments, adequacy decisions are adopted or challenged and suppliers restructure. If your assessment relies on outdated assumptions, the transfer may no longer meet the standard you documented.
Regulators expect the assessment to be maintained. The EDPB recommendations on supplementary measures say that exporters should monitor, on an ongoing basis and where appropriate with importers, developments in the third country that could affect the initial assessment. Sound TIA review and monitoring shows that you did exactly that.
Most organizations review each TIA at least once a year, with additional reviews for higher-risk transfers, such as those involving sensitive data or countries with active legal change. Add the date to a register, name an owner and set reminders.
Scale the effort to the risk. A low-risk transfer of limited data to a country with an adequacy decision might need a short confirmation. A high-risk transfer to a cloud provider in a country with broad surveillance powers might need a full reassessment with legal input. Keep a simple register of all transfers with their tools, measures and next review date.
Free transfer impact assessment
Can this transfer of personal data go ahead?
Check whether the transfer needs a TIA, map it, assess the laws and practice of the destination, rate the risks from 27 transfer scenarios and choose supplementary measures. Covers the EU SCCs and the UK IDTA and Addendum, free.
Do not wait for the annual date if something important changes. Build triggers into procurement, change management and legal monitoring: changes in destination law or case law, adoption or challenge of adequacy decisions, changes to standard clauses or transfer tools, supplier changes and incidents.
Assign someone to monitor legal developments, or subscribe to updates from your supervisory authority and trusted law firms. Route relevant news to the TIA owner. Our overview of the Data Privacy Framework and TIAs shows how a change in an adequacy mechanism affects the assessment.
| Review trigger | Example | What to check |
|---|---|---|
| Change in destination law | New surveillance or data access legislation | Whether protection is still essentially equivalent |
| Change in transfer tool status | Adequacy decision adopted, amended or invalidated | Whether the tool still applies or needs replacing |
| Supplier change | New hosting location or sub-processor | Data flows, contract and measures |
| New data or purpose | Adding sensitive data to the transfer | Risk and measures |
| Incident or access request | Government request received by the importer | Effectiveness of measures and contract commitments |
| Scheduled cycle | Annual review | Everything above |
Revisit the assessment of the destination country’s laws and practices. Have new laws been passed that give authorities wider access? Have safeguards, oversight bodies or redress mechanisms changed? Has case law altered how the rules are applied? Use reliable sources and record them.
Compare the result with the earlier assessment and note any change. If the country’s position has worsened, consider whether your supplementary measures still work. If it has improved, for example through an adequacy decision, you may be able to simplify. See transfer impact assessment of third-country laws for the method.
Confirm the facts of the transfer: the data, the recipients, the locations and the sub-processors. Ask whether anything has changed, and whether the supplier has received government access requests and how it responded. Review its transparency reporting and its commitments in the contract.
Check that measures still operate as described. Encryption keys still under your control? Access logs still reviewed? Pseudonymisation still effective? Our guides to TIAs for sub-processors and TIAs for cloud services list the questions to ask.
For each measure, ask whether it is still effective given any change in law, technology or the supplier’s set-up. For example, an encryption design that was strong may need updating for new algorithms, or a key management arrangement may have changed. See supplementary measures for data transfers and encryption as a supplementary measure for the analysis.
If a measure no longer works, decide what to do: strengthen it, add another, change the design, move the processing or suspend the transfer. Record the decision and the reasoning.
Every review should produce a dated record, even if nothing changes. A short entry might read: “reviewed 15 March; no change in law or supplier; measures confirmed; next review March next year”. Where something changes, update the TIA itself, keep the earlier version and note the reason.
Have the accountable owner approve the result, with input from the DPO and legal. If the review shows that the transfer can no longer be supported, escalate promptly and follow the suspension or termination steps in your contract and plans.
Give ownership of the process to the person accountable for the transfer or the relationship, with the DPO advising and legal providing analysis on the destination country. Security should confirm technical measures, and procurement should manage supplier contact.
Keep responsibilities in a short RACI or table, and report overdue reviews to a governance forum. Overdue reviews are an easy indicator of drift. Link the review to your record of processing, as described in international transfers in the ROPA, so the two stay consistent.
Typical problems include doing the assessment once and never revisiting it, monitoring the law informally with no record, missing supplier changes, assuming an adequacy decision removes any need for review, failing to keep earlier versions and forgetting to check that measures still work. Another is relying on supplier assurances without evidence.
Avoid these with a register, clear triggers, a named owner and a habit of recording every review. An example of a complete record can be found in our transfer impact assessment example.
Give leaders a brief summary of the transfer portfolio each year: number of transfers, tools used, reviews completed, changes found and any transfers suspended or at risk. Highlight countries where the legal position is moving and suppliers whose set-up changed. A short dashboard is enough. It keeps international transfers on the governance agenda and helps management fund the follow-up work, such as changing suppliers or upgrading measures.
Use the results to improve the process itself. If the same trigger keeps being missed, add a control upstream. If reviews consistently find no change for a low-risk transfer, consider lengthening the cycle for that category and documenting the reasoning.
A shared register, calendar reminders and a short review template are enough for most teams. Add a field for the last review date, the next review date, the owner and the trigger that prompted the last change. If you use a vendor management platform, link each transfer to the supplier record so that supplier changes raise alerts automatically.
A software company transfers support data to an affiliate in a third country under standard contractual clauses, with encryption and access controls as supplementary measures. At the annual review, the team notes that the affiliate has moved a support team to a new location and that a new sub-processor handles ticket storage.
The team asks for updated information, reviews the destination law for the new location, confirms that keys remain in the exporter’s region and updates the assessment. It records the changes, obtains approval and sets the next review date. The whole exercise takes two days and shows that the transfer is still under control.
If you want a report and workbook that hold the transfer description, legal analysis, measures, review log and sign-off, the Transfer Impact Assessment Report and Workbook provides a structured layout for this work. Whatever tool you use, disciplined TIA review and monitoring means watching for change, checking what matters and recording what you decide.
At least annually, and whenever there is a change in the destination country’s law, the transfer tool, the supplier set-up or the data involved. Higher-risk transfers may need more frequent review.
It changes the analysis, but you should still monitor its status and confirm that the transfer stays within its scope.
A designated person in privacy or legal, using supervisory authority updates and trusted legal sources, with relevant news routed to the TIA owner.
Strengthen the measures, change the design, move the processing or suspend the transfer, and record the decision and reasoning.
Yes. Keeping dated versions lets you show how the assessment evolved and why decisions were made.
September 30, 2026
