Transfer Impact Assessments (TIAs) – Navigating International Data Transfers 2025

One significant addition to the CIPP/E Exam September 2025 is the Transfer Impact Assessment (TIA). In an era of global data flows, TIAs have become essential for GDPR compliance. A TIA is essentially a risk assessment for cross-border data transfers. Under GDPR’s rules, before sending personal data outside the EEA, an organization must ensure the destination provides “EU-equivalent” data protection. TIAs help determine if a transfer tool like Standard Contractual Clauses (SCCs) will work or if extra safeguards are needed. This process was emphasized after the Schrems II case invalidated the EU–US Privacy Shield. The European Data Protection Board (EDPB) recommends a structured six-step TIA process. In simple terms, organizations should:

• Know your transfers: Identify what data you’re sending, where, and who will receive it.
• Choose a transfer tool: Often SCCs, which are EU-approved contract clauses for data exports.
• Assess destination laws: Evaluate the third country’s laws to see if they might undermine the protections in the SCCs (e.g. excessive government surveillance).
• Adopt supplementary measures if needed: If the legal environment is risky, add extra safeguards like encryption or data storage in the EU.
• Take procedural steps: Follow any formalities (like getting management sign-off or notifying authorities in certain cases).
• Re-evaluate periodically: Monitor the situation and redo the TIA if circumstances change.

By performing a TIA, controllers can document the transfer’s circumstances, the destination country’s privacy laws, and what safeguards are in place. In fact, the latest SCCs explicitly require conducting and documenting such a TIA. TIAs are now a fixture in privacy practice – and the CIPP/E exam – because they show regulators (and your customers) that you’ve thought through the risks of sending personal data abroad and taken steps to protect it. With new developments like the EU–US Data Privacy Framework (which restored a lawful transfer path to the U.S.), understanding TIAs is crucial for any privacy professional.

Sources:

1. IAPP, Q3 2025 CIPP/E Exam Updates (listing new topics like EDPB Opinions 22/2024 and 04/2024, Guidelines 1/2024, AI and security incidents)[47].
2. EDPB, SME Guide on International Transfers (noting SCCs require a “transfer impact assessment” of transfer context, destination law, and safeguards)[2].
3. TermsFeed, Transfer Impact Assessment (TIA) (explaining TIAs as a six-step process per EDPB Recommendations)[48].