What this control covers
Maintain a register of all international data transfers (country, processor, data category, volume, transfer mechanism). Implement a screening process to verify that no transfers are made to countries on the government's restricted list. Subscribe to government regulatory notifications to receive updates to the restricted country list. Review all SaaS and cloud providers for data storage locations. Objective: Prevent transfers of personal data to restricted countries and maintain a comprehensive audit trail of all cross-border data flows.
Why it matters
Encryption and key management make data unreadable to attackers and unintelligible under data-breach safe-harbour clauses — a meaningful regulatory benefit.
How to implement
AWS
Default to SSE-KMS with customer-managed keys for S3/EBS/RDS/Secrets Manager. Use S3 Bucket Keys and S3 Block Public Access at the account level, and turn on S3 Object Lock on backup buckets for ransomware resilience.
Azure
Store secrets in Key Vault (HSM-backed where required) with soft-delete + purge protection; use customer-managed keys for Storage, SQL, and Azure Disk Encryption. Tag PII data via Microsoft Purview.
GCP
Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.
Google Workspace
Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
policy_document— A signed, version-controlled policy stating leadership intent and the named owner.vendor_risk_management— See the iCompaas Evidence library for the canonical source for this evidence type.
Signed policies, procedures, and registers document the safeguard. Processor due diligence, DPAs, and transfer registers evidence third-party controls. Focus: International Data Transfer Register & Restriction Screening.
Quick checklist
- Maintain — International Data Transfer Register / Restriction Screening
- Implement — International Data Transfer Register / Restriction Screening
- Provide — International Data Transfer Register / Restriction Screening