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T04 Data Location and International Transfer Record

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Field Entry
System ID
Date; valid until (re-attest on change or at 12 months)
Signer

1. Locations

Component Description Country Provider and region Legal entity Encrypted Key holder
Training data
Fine-tuning data
Prompts and inputs
Inference compute
Outputs
Embeddings / vector store
Logs (including AI Act logs)
Telemetry
Backups
Support and admin access
Sub-processors

2. Transfers outside the EEA

Flow From To Personal data? Mechanism (adequacy decision, standard contractual clauses, binding corporate rules, derogation) Transfer impact assessment done Supplementary measures Approved by

Confirm the current adequacy list, and any framework with the US, from the primary source. These change.

3. Remote access

Can staff or support outside the EEA see the data? Record the controls and the logging.

4. Attestations

  • [ ] Components are at the stated locations
  • [ ] No replication elsewhere
  • [ ] Customer data is not used for supplier training
  • [ ] Deletion reaches backups within ___ days
  • [ ] Evidence attached (region settings, exports)
  • [ ] Data Act cloud-switching or portability terms reviewed where relevant [Recalled]

Exceptions and compensating controls: ______

5. Sign-off

Role Name Date
Signer
Privacy and security reviewer