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INTERNATIONAL TRANSFERS GUIDE

How to Conduct a Transfer Impact Assessment (TIA) / Transfer Risk Assessment (TRA)

Map the international transfer, identify the condition, assess destination and recipient risk, and document safeguards and residual risk.
Use the working sequence below to connect the decision to operating implications, retained evidence and the point where specialist DPO support may be required.
Start the TIA/TRA guide

Prepared by DPO Arabia

Practical KSA PDPL guidance, not organisation-specific legal advice.

DPO Arabia PDPL DPO Guides

KSA PDPL GUIDE

Assess the transfer route, foreign-access risk and safeguards before Personal Data leaves the Kingdom.

The Guide frames the transfer purpose, destination, recipient, legal route, risk analysis and safeguards that should support the cross-border decision. The organisation-specific conclusion should be validated before implementation.

USE THIS WHEN

Use when Personal Data will be transferred, hosted or accessed outside the Kingdom.

This becomes relevant before processor onboarding, when scope changes, when a contract is renewed or when existing terms no longer match the processing.

HAVE READY

Bring the transfer facts, recipient details, data flows, contracts and security controls.

Useful inputs include the Record of Processing Activities (RoPA), processor or recipient information, locations, access model, Standard Contractual Clauses (SCCs) or other safeguards, retention terms and technical controls available.

OUTCOME

Finish with a documented TIA / TRA and a clear decision on whether the transfer may proceed.

A complete evidence set retains the transfer route, risk assessment, safeguards, owner approvals, contractual dependencies and reassessment triggers.

HOW TO USE THIS GUIDE

Use the Guide to frame the decisions before implementation.

This Guide highlights the decisions, evidence and operating interfaces that should be resolved before the requirement is treated as complete.

Use it to understand the issue, challenge the relevant facts and identify where organisation-specific legal, operational or technical input is needed.

GUIDE OUTCOME

A transfer assessment that explains the route, risk, safeguards and decision to transfer Personal Data.
The objective is a defensible decision and an operating control, not simply a completed template or document.

QUESTIONS TO RESOLVE

What should the DPO Office establish?

  • MAP TRANSFER
  • CONFIRM TRANSFER BASIS
  • ASSESS DESTINATION RISK
  • TEST SAFEGUARDS
  • RECORD RESIDUAL RISK
  • SET REASSESSMENT

TRANSFER ASSESSMENT CHECKPOINT

01

What Personal Data is transferred, hosted or remotely accessed outside Saudi Arabia, by whom and from where?

02

What is the transfer purpose, destination and relationship between exporter and recipient?

03

What transfer condition and safeguard route apply?

04

What risks arise from the destination, recipient, foreign access and onward-transfer chain?

05

Are the safeguards sufficient, approved, evidenced and subject to reassessment?

WORKING STEPS

Use the sequence to identify the decisions that need to be resolved.

01

Map the real international transfer chain

Identify the exporter, importer, recipient role, destination country, Personal Data, Data Subjects, transfer purpose and frequency.

A service provider incorporated in one country may host or support the service from several others.

What to validate in practice

  • Identify the exporter, importer and the role each party performs for the specific transfer.
  • Map the Personal Data, Data Subjects, purpose, frequency, systems and integrations involved.
  • Confirm hosting, backup, disaster recovery, support, administration and employee access locations.
  • Identify sub-processors, onward recipients and any further international access in the service chain.
  • Check whether the contracting entity differs from the entity that actually hosts, supports or processes the Personal Data.
  • Reconcile the transfer chain with the RoPA, Processor or Controller assessment, contracts and technical architecture.
Regulatory lens: Saudi PDPL Article 29 – Cross-Border Personal Data Transfers and Disclosures

DPO Arabia service

Explore Transfer Impact / Risk Assessment (TIA / TRA)

WHAT NOT TO DO

Do not assess only the service provider’s country of incorporation. Map hosting, remote access, support teams, sub-processors and onward-transfer locations.
02

Identify the transfer condition and safeguard route

Determine why the transfer is permitted under the PDPL transfer framework and whether adequacy, an exemption or an appropriate safeguard is relied upon. Do not select SCCs automatically before understanding the legal route and the parties’ roles.
Document the legal transfer condition separately from the operational business purpose.

What to validate in practice

  • Document the operational business purpose separately from the legal condition permitting the transfer.
  • Confirm whether the transfer falls within a permitted purpose under the KSA PDPL transfer framework.
  • Assess whether an exemption or adequacy route applies before selecting an appropriate safeguard.
  • Determine whether a transfer risk assessment is required for the specific route and circumstances.
  • Confirm exporter and recipient roles before selecting any role-specific contractual mechanism.
  • Record why SCCs, BCRs or another safeguard route is appropriate rather than treating the mechanism as automatic.
Regulatory lens: Regulation on Personal Data Transfer outside the Kingdom

DPO Arabia service

Explore Cross-Border Transfer & Disclosure Compliance

TRANSFER CONDITION

Separate the business purpose from the legal transfer condition and document the safeguard route before selecting contractual measures.
03

Assess destination, recipient and access risk

Evaluate the destination environment, recipient characteristics, foreign-law exposure, likelihood and nature of government or third-party access, onward transfers and practical enforceability of safeguards. Consider the type and sensitivity of Personal Data and consequences for Data Subjects.
The assessment should be specific to the transfer, not a generic country-risk paragraph.

What to validate in practice

  • Assess the destination legal and regulatory environment relevant to the transfer and recipient.
  • Evaluate the recipient type, ownership, jurisdictional exposure and practical ability to comply with safeguards.
  • Consider the likelihood and nature of access by public authorities or other third parties.
  • Assess sensitivity, scale, frequency, identifiability and potential consequences for affected Data Subjects.
  • Evaluate sub-processor and onward-transfer risk, including any additional countries or access locations.
  • Support assumptions with recipient, legal, technical or contractual evidence rather than generic country-risk statements.
Regulatory lens: Risk Assessment Guideline for Transferring Personal Data Outside the Kingdom – Third: Risk Assessment for Data Transfer or Disclosure to Entities Outside the Kingdom

DPO Arabia service

Explore Transfer Impact / Risk Assessment (TIA / TRA)

RISK LENS

Use the actual recipient, destination, access model and Personal Data involved. Avoid generic country-risk wording that could apply to any transfer.

04

Evaluate technical, organisational and contractual safeguards

Review encryption, key control, access restrictions, data minimisation, pseudonymisation, logging, retention, incident response, onward-transfer restrictions and contractual commitments. Determine whether supplementary measures are needed to bring residual risk to an acceptable position.

Where SCCs are used, ensure the completed appendices match the controls actually assessed.

What to validate in practice

  • Evaluate encryption in transit and at rest, including who controls the relevant encryption keys.
  • Assess access restriction, privileged access, authentication, logging and monitoring for foreign access.
  • Consider data minimisation, pseudonymisation, retention and deletion controls that reduce transfer exposure.
  • Review incident response, Data Subject Rights support, onward-transfer and sub-processor restrictions.
  • Confirm contractual safeguards, audit or assurance rights and supplementary measures address the risks identified in the TIA / TRA.
  • Where SCCs are used, verify that the selected template, appendices and described safeguards match the actual roles, transfer and controls.
Regulatory lens: Standard Contractual Clauses (SCCs) For Personal Data Transfer – Rules

DPO Arabia service

Explore SDAIA Standard Contractual Clauses

SAFEGUARD CHECK

Evaluate encryption, access restrictions, key control, logging, minimisation, retention and onward-transfer restrictions alongside contractual safeguards.
05

Approve, register and reassess the transfer

Record residual risk, conditions, approvals and the transfer safeguard. Link the TIA/TRA to the RoPA, disclosure/transfer register, Processor record, Data Processing Agreement (DPA) or Data Sharing Agreement (DSA) and executed SCCs where relevant.

International transfer governance should remain live after contract signature.

What to validate in practice

  • Record the residual risk and the final approval, rejection or conditional approval decision.
  • Record the residual risk and the final approval, rejection or conditional approval decision.
  • Retain the executed SCCs, BCRs or other applicable transfer mechanism and link them to the assessment.
  • Update the RoPA, transfer or disclosure register, Processor or Controller record and the relevant DPA or DSA.
  • Define reassessment triggers for new countries, sub-processors, purposes, support locations, system changes or material legal developments.
  • Assign a review date and ensure the current approved TIA / TRA version and supporting evidence remain retrievable.
Regulatory lens: Regulation on Personal Data Transfer outside the Kingdom

DPO Arabia service

Explore Cross-Border Transfer & Disclosure Compliance

KEEP IT LIVE

Set reassessment triggers for new countries, sub-processors, processing purposes, support locations or material legal changes.

EVIDENCE TO RETAIN

Know what evidence should remain after the work is complete.

Retain the transfer map, recipient and location details, assessment rationale, safeguards, contractual mechanism, security evidence, approvals and reassessment trigger that support the transfer decision.

RETAINED EVIDENCE SET

Keep the transfer mapping, assessment and selected safeguards in one defensible record.
Retain approvals, supplementary measures and reassessment triggers.
Approved TIA / TRA
Transfer-chain map
Exporter and recipient role determination
Personal Data and Data Subject mapping
Transfer purpose
Destination and access locations
Hosting, backup and support-location evidence
Sub-processor and onward-transfer mapping
Transfer-condition assessment
Safeguard-selection rationale
Destination and recipient risk assessment
Foreign-law and access assessment
Technical safeguards
Organisational safeguards
Contractual safeguards
SCCs or other transfer safeguard, where applicable
Supplementary measures
Residual-risk decision
Approval and conditions
RoPA linkage
Transfer / disclosure register entry
DPA / DSA linkage
Reassessment trigger and review history

BEFORE YOU CLOSE THE WORKFLOW

Validate the operating position, not only the document.

Before closing the TIA / TRA, confirm that the transfer facts are complete, the applicable route is clear, material risks are addressed, safeguards are documented and future change triggers are defined.
Use the checks below to test whether the transfer decision can be reconstructed from the data flow, recipient facts, risk analysis, safeguards and contractual evidence.

FROM GUIDANCE TO OPERATION

Connect the decision to the wider DPO Office.

A TIA / TRA becomes operational when transfer facts, safeguards, contracts, technical controls and reassessment triggers remain connected to the live international processing arrangement. Use this handoff to keep transfer governance current.

01

Apply the DPO guide

Use the guide to map the transfer, identify the applicable route, assess risk, define safeguards and document the approval or remediation decision.

03

Connect the controls

Connect the TIA / TRA to the RoPA, transfer and disclosure records, Processor or Controller relationship, DPA or DSA, SCCs, supplementary measures and reassessment triggers so the transfer remains traceable throughout its lifecycle.

03

SPECIALIST SUPPORT

Get specialist support

Use DPO Arabia to conduct or review transfer assessments, challenge risk assumptions, define supplementary safeguards or connect the assessment to SCCs and wider transfer governance.

GUIDE STEPS

Use these sections as your working path through the DPO guide. If a processing fact is unknown, record it for clarification rather than guessing.

01
How to use this guide
 02
Questions to resolve
 03
Working steps
01
Map the real international transfer chain
02
Identify the transfer condition and safeguard route
03
Assess destination, recipient and access risk
04
Evaluate technical, organisational and contractual safeguards
05
Approve, register and reassess the transfer
04
Evidence to retain
 05
Before you close
 06
From guidance to operation

READY TO OPERATIONALISE IT?

Need to turn the guidance into an operating DPO Office control?

DPO Arabia can apply the Guide to your organisation’s actual processing, decisions and evidence, then implement and operate the resulting control through the appropriate DPO Office service.

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