Template for assessing a transfer of data abroad (TIA)

  • Art. 16-17 FADP
  • Art. 44-49 GDPR
  • About 45 minutes
  • Italiano · Deutsch · Français · English

In brief

The worksheet by which you assess a transfer of data to a country without adequate protection: on what basis it takes place, what the law of the country provides and which measures you add. You need it before entrusting data to a recipient in such a country.

Who it is for
Internal use: the internal contact and management. It is kept with the supplier's contract and shown to the authority on request.
To decide first
Who receives the data and in which country; then you describe the transfer, its basis (for example standard clauses), the risks of the country and the supplementary measures.
Afterwards
Have it approved, link it to the vendor concerned and repeat it if the supplier, the data or the situation in the country changes.

What it contains

  1. 1When to use this worksheet
  2. 2Description of the transfer
  3. 3Necessity of the transfer
  4. 4Basis of the transfer
  5. 5Law and practice of the country of destination
  6. 6Supplementary measures
  7. 7Residual risk
  8. 8Conclusion
  9. 9Review
  10. 10Approval

An excerpt

1. When to use this worksheet

A worksheet is completed for every transfer of personal data to a country that does not guarantee adequate protection, before the transfer begins. Remote access to the data from that country (for example for technical support) and storage with a cloud provider that processes the data abroad also count as a transfer.

For Switzerland, disclosure abroad is governed by Art. 16-17 FADP. The countries with adequate protection are listed in Annex 1 to the Data Protection Ordinance.

For the European Union, transfers to a third country are governed by Art. 44-49 GDPR. The countries with adequate protection are those covered by an adequacy decision of the European Commission; Switzerland is one of them.

The full text is generated on the platform, with your organisation's details already in place.

FADP and GDPR compared

FADP (Switzerland)GDPR (EU)
Adequate countriesList of the Federal Council (Annex 1 Data Protection Ordinance)Adequacy decisions of the Commission (Art. 45 GDPR)
Without adequacyAppropriate safeguards, such as standard data protection clauses recognised by the FDPIC (Art. 16 para. 2 FADP)Appropriate safeguards, such as standard contractual clauses (Art. 46 GDPR)
DerogationsArt. 17 FADP, for example explicit consent or performance of a contractArt. 49 GDPR, interpreted restrictively

The template adapts itself: it picks the paragraphs by the laws that apply to your organisation.

Related templates

Related question: Can I use vendors with servers in the United States or the EU?

A template is general information, not advice on your case: it must be adapted to your organisation. For a question on your case there is Advisorn's consulting. By Advisorn, updated on 20 October 2026.