Guest user Created: Nov 28, 2018 Last commented: Nov 28, 2018

Data transfer outside of the EU

We're a digital-currency exchange start-up. Currently, we're working on developing the user onboarding process, as part of which we ask users to upload proof of identity and other documents. The document storage solution is provided by an external tech company. They do not process the files, but simply provide storage on their servers which are located in EU. However, the service provider is incorporated in the USA. My main question is, does this equate to a restricted transfer under GDPR. We're also in need of ongoing advice on an ad-hoc basis with regards to meeting GDPR compliance.

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Andrei Hanganu Nov 28, 2018

Answer:

Based on your description, if the servers are in EU and the data does not leave those servers in order to be sent to the mother company in the US, there is no cross-border data transfer. I would also assume that the storage is provided via an affiliate of the EU based company of a subcontractor of the US company.

If you want to find out more about cross-border data transfers check out this webinar: “How to make personal data transfers to other c ountries compliant with GDPR” (https://advisera.com/webinars/how-to-make-personal-data-transfers-compliant-with-gdpr-free-webinar-on-demand/).

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Nov 28, 2018

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