UK Data Bridge — US Transfers Compliance Template

The UK-US Data Bridge (extension of the EU-US Data Privacy Framework) allows UK organisations to transfer personal data to certified US organisations without additional safeguards. This template covers how to use the Data Bridge correctly and what to do when it is not available.

Quick Answer

The UK-US Data Bridge, effective October 2023, allows UK-to-US personal data transfers where the US recipient holds a valid DPF certification with the UK Extension. Unlike the EU-US DPF, it is a bilateral UK agreement. Organisations must verify recipient certification and maintain fallback transfer mechanisms.

Compliance Checklist (8 items)

Verify the US recipient is certified under the Data Privacy Framework and the UK Extension — check the DPF list at dataprivacyframework.gov
Confirm the transfer falls within the scope of the recipient's DPF certification
Document the transfer in your Record of Processing Activities including the Data Bridge as the transfer mechanism
Do not rely on the Data Bridge for transfers to sub-processors unless they are also DPF-certified
Put an IDTA or UK Addendum in place as fallback for any recipient not covered by the Data Bridge
Monitor for DPF certification lapses — certifications must be renewed annually by the recipient
Conduct a Transfer Risk Assessment if sensitive or special category data is involved
Update your privacy notice to inform data subjects of transfers to the US under the Data Bridge

Penalty if not compliant

Unlawful international transfers are a serious UK GDPR infringement. ICO fines up to £17.5 million or 4% of global turnover. The ICO can also compel suspension of transfers.

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UK-US Data BridgeData Privacy Framework UKinternational data transfersUK GDPR transfersIDTAUS data transfers UK