What this control covers

Inform customer timely of basis for transfers between jurisdictions and intended changes. Implementation: Notify customers; document transfer basis and any agreements used (SCCs, BCRs). Justification: Customer needs to be able to object or terminate contract.

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

Operate a Records of Processing Activity (RoPA) and a data-subject-request (DSR) workflow with named owners, SLA per regulation (GDPR 30 days, DPDP 30 days, CCPA 45 days). iCompaas users can track requests + evidence inside the Privacy module.

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, contracts, and disclosure registers evidence third-party controls. Focus: Basis for transfer.

Quick checklist

  • Implement — Basis For Transfer
  • Document — Basis For Transfer
  • Notify — Basis For Transfer

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