Happy New Year? A look at the ICO's new 'international data transfers' guidance

Rob looks at the ICO’s newly released guidance on international transfers and what it means for UK privacy professionals.• The “Three-Step Test” for identifying restricted transfers• Why UK processors returning data to overseas controllers are no longer “initiating” transfers• Clarifications on transfers between branches and employees within the same legal entity• How the guidance incorporates the Data (Use and Access) Act while retaining “TRA” terminology• The distinction between legal entities and server locations in cloud service contracts