GDPR Article 47 — Binding corporate rules

What this control requires

Binding Corporate Rules (BCRs) must be approved by the supervisory authority, ensuring legal bindingness, enforceable data subject rights, and compliance with GDPR principles. BCRs specify data transfer details, security measures, data subject rights, complaint procedures, audits, and cooperation with authorities. This control addresses International Data Transfers.

In plain English

Binding Corporate Rules (BCRs) must be approved by the supervisory authority, ensuring legal bindingness, enforceable data subject rights, and compliance with GDPR principles. In practice, this means you can prove you principles transfers-level controls on a defined cadence.

Why it matters

GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.

What an auditor looks for

A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.

Within Chapter V: Transfers of Personal Data to Third Countries, the assessor will trace your implementation back to the catalogue reference (Article Article 47) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Principles. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Cooperation. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Transfers. Document the trigger, the owner and the cadence.
• Scope: transfers, security measures, supervisory authority, corporate rules, rights.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Binding corporate rules.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• HIPAA (45 CFR Part 164) 164.312(a)(1) — Access Control

Related controls in GDPR

• Article Article 46 — Transfers subject to appropriate safeguards
• Article Article 51 — Supervisory authority
• Article Article 53 — General conditions for the members of the supervisory authority
• Article Article 48 — Transfers or disclosures not authorised by Union law
• Article Article 54 — Rules on the establishment of the supervisory authority
• Article Article 55 — Competence

References

• European Union — GDPR
• Catalogue identifier: Article Article 47

Topics: governance riskpolicy management