I am having a hard time understanding the requirements for the cross border personal data transfer procedure. If personal data is stored electronically, yet is only accessible within your organization, does that mean it falls under this policy? As an example, we have an HR system with information on UK employees. HR staff in the US can access this. However, the data is not being sent to a third party; it is all retained within our organization. Is this considered a cross border transfer, or not?
First of all I would like to mention that cross border transfer refers to the situation where personal data is stored or accessed from outside the EEA. So in your case if the data is stored in UK but it can be accessed from the US than it is definitely a cross border data transfer.