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Mastering Transfer Impact Assessments: Key Insights from CNIL’s Final Guidelines

February 12, 2025

The French Data Protection Authority (CNIL) released its final guidelines on Transfer Impact Assessments (TIAs) on January 31st 2025, offering a comprehensive roadmap for organizations to comply with the GDPR when transferring personal data outside the EEA and third countries not deemed adequate by the European Commission. Here are the major key takeaways:

1

Responsibilities on Carrying Out TIAs The CNIL clarifies that, it is primarily the data exporter responsibility (no matter wheter it is a Controller or Processor) to conduct TIAs. Data importer must assist the exporter by demonstring compliance with GDPR. Such assistance includes providing third country law assessment – providing executive summary is not sufficient
2

Comprehensive Data Flow Mapping A crucial first step is identifying and mapping all international data transfers, including any sub-processors or service providers. This visibility helps organizations understand exactly where and how data is moving
3

Contextual Risk Evaluation The CNIL emphasizes a case-by-case assessment of local laws and surveillance powers in the destination country. This granular approach helps determine whether existing transfer tools (e.g., SCCs) sufficiently protect personal data, or if supplementary measures are needed
4

Supplementary Measures Where risks are identified, technical (e.g., encryption, pseudonymization), contractual, or organizational measures must be implemented to ensure data protection equivalent to EU standards. These measures should be tailored to the specific context of each transfer
5

Transparency & Accountability Organizations need to document their TIA process—including the results of assessments and the rationale behind chosen measures—to demonstrate accountability. This documentation is crucial for regulatory inquiries and for building trust with data subjects
6

Ongoing Monitoring & Review TIAs should be regularly updated to address changes in legal frameworks, data flows, or business operations. Continuous monitoring ensures that data remains protected over time

By following these guidelines, organizations can bolster their data protection posture and mitigate compliance risks. Ensuring TIAs are conducted diligently—and updated when necessary—demonstrates a strong commitment to GDPR broadly and data transfer requirements more specifically.

MyData-TRUST’s team is ready to support you with expert guidance on every aspect of Transfer Impact Assessments (TIAs).

Winnie Dongbou

Senior Data Protection Lawyer

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