Cross-Border Transfers and Breach Readiness: Cloud Regions, LLM Providers, Standard Contracts and the 72-Hour Notification
A transfer abroad is not only where the server is; logs, backups, e-mail, analytics and LLM prompts are transfers too, and since 2024 they must rely on an adequacy decision, an appropriate safeguard such as a standard contract, or an occasional case. On Bookstore we keep the sub-processor inventory in code, check the five-business-day notification of standard contracts at start-up, and use an access log to get a breach's scope and the 72-hour deadline within the first hour.
15 Nov 2026
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11 min
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5