EDPB Guidelines 05/2021: when a disclosure is a 'transfer' under Chapter V (EDPB Guidelines 05/2021 on the interplay between Article 3 and Chapter V, Version 2.0, adopted 14 February 2023, executive summary)
A transfer needs personal data, an exporter under the GDPR, and an importer outside the EU. If the data sent is truly anonymous there is no personal data and so no transfer; if it is only pseudonymised the holder should still treat it as one.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“1) A controller or a processor ("exporter") is subject to the GDPR for the given processing. 2) The exporter discloses by transmission or otherwise makes personal data, subject to this processing, available to another controller, joint controller or processor ("importer"). 3) The importer is in a third country, irrespective of whether or not this importer is subject to the GDPR for the given processing in accordance with Article 3, or is an international organisation.”
Where it was read
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