SCC Transfer Impact Assessment Tool

Assess third-country transfer risk for GDPR Standard Contractual Clauses

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An SCC Transfer Impact Assessment tool that turns the Schrems II obligation into a repeatable scorecard. After Schrems II struck down Privacy Shield, you can no longer rely on Standard Contractual Clauses alone: you must assess whether the destination country’s surveillance laws undermine those clauses and, if they do, add supplementary measures. This tool walks you through the EDPB’s six-step methodology and returns a risk band plus the concrete measures to apply, for legal counsel and international data-transfer teams.

How it works

The assessment follows the EDPB Recommendations 01/2020 on supplementary measures:

Step 1  Know your transfer (destination, data, importer)
Step 2  Identify the transfer tool (here: SCCs)
Step 3  Assess local law and practice (surveillance, rule of law)
Step 4  Identify and adopt supplementary measures
Step 5  Take procedural steps to implement them
Step 6  Re-evaluate at intervals

The tool encodes Step 1 and Step 3. First it checks the destination against the list of countries with an EU adequacy decision (UK, Switzerland, Japan, South Korea, Canada-commercial, New Zealand, and others); if adequate, the transfer needs no SCCs and the assessment ends. Otherwise it scores three risk inputs: the rule-of-law / surveillance exposure of the country, the sensitivity of the data, and whether strong encryption removes the importer’s ability to read plaintext.

Reading the score and measures

The three inputs combine into a low, medium or high band. The decisive factor, per the EDPB, is whether a technical measure — encryption where the importer never holds the keys, or pseudonymisation that cannot be reversed at the destination — makes any government access ineffective. When that is in place, even a high-surveillance destination can drop to acceptable risk. When it is not, the tool recommends layering technical, contractual (transparency, audit, challenge obligations) and organisational measures, and warns when the residual risk means the transfer should not proceed without legal sign-off.

This is guidance, not legal advice, and everything is computed locally — no transfer details ever leave your browser.

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