Extract to table

The Company must comply with both regimes across the full range of its data processing operations

Where a single data flow contains both UK and EU personal data — which is common in NTP's unified NorthCloud infrastructure, where subscriber data from multiple jurisdictions flows through shared pipelines — both sets of clauses must be in place and properly executed

NTP must ensure that its third-country data importers (principally Caldwell Analytics Inc

Transfer documentation negotiations with Caldwell's external counsel, Hargrove Lister & Webb LLP (Natalie Prescott, Partner, Data Privacy & Cybersecurity; 555 Mission Street, Suite 3100, San Francisco, California 94105; London office at 30 Fenchurch Street, London EC3M 3BD), are currently in progress and must accommodate both the UK and EU regimes

The EDPB Recommendations set out a six-step assessment framework that data exporters must follow

Accordingly, NTP's TIAs must address the requirements of both the EDPB Recommendations (for EU-origin transfers) and the ICO TIA guidance (for UK-origin transfers)