Extract to table

The engagement of these sub-processors gives rise to international data transfer obligations that must be addressed through appropriate transfer mechanisms, including EU SCCs (Module 3, processor-to-processor) and/or the UK Addendum to the EU SCCs, as applicable

These SCCs must be supplemented by the completion of a comprehensive Transfer Impact Assessment and the documentation and implementation of appropriate supplementary measures

A comprehensive TIA must be conducted for the NTP-to-Caldwell data flow

2 Factors Affecting Fine Calculation (Article 83(2)) Article 83(2) of the EU GDPR sets out a non-exhaustive list of factors that supervisory authorities must take into account when determining the amount of any administrative fine

These obligations may conflict with GDPR Article 5(1)(e) (storage limitation) and Article 5(1)(c) (data minimisation), and must be carefully managed through appropriate legal basis analysis and data retention policies