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
Related articles on this site
- NIST 800-171 3.4.4 Analyze the security impact of changes prior to implementation.
- NIST 800-171 3.4.5 Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.
- CMMC 2.0 CM.2.066 Analyze the security impact of changes prior to implementation.
- CMMC 2.0 CM.3.067 Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.