Some key takeaways from a discussion earlier this week were:
- Conduct a data inventory and document ALL data flows.
- Confirm ALL data hosting locations, for live and back-up systems.
- Confirm residences and nationalities of data subjects.
- Assign cross-boarder policies.
- Monitor actively cross boarder data flows – with software tool.
- Prepare a plan of action with steps for out of policy data flows and transfers.
- Prepare a data driven “Third Party/ Country Data Transfer Summary Report”
- Watch this space – keep your eye on regulatory developments.





