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International Data Transfer Addendum
"I need an International Data Transfer Addendum under Pakistani law for transferring healthcare data from our Karachi-based medical facility to a cloud service provider in Germany, with implementation planned for March 2025."
1. Parties: Identification of the data exporter and data importer, including their full legal names, registration details, and addresses
2. Background: Context of the data transfer relationship and reference to the main agreement this addendum supplements
3. Definitions: Key terms used in the addendum, including specific Pakistani law terminology and international data protection concepts
4. Scope and Purpose: Details of the types of personal data being transferred, processing purposes, and transfer mechanisms
5. Data Protection Safeguards: Security measures and controls implemented to protect personal data during transfer and processing
6. Obligations of the Data Exporter: Responsibilities and commitments of the party sending the data, including compliance with Pakistani data protection laws
7. Obligations of the Data Importer: Responsibilities and commitments of the party receiving the data, including maintaining appropriate security measures
8. Data Subject Rights: Procedures for handling data subject requests and ensuring rights under Pakistani law are respected
9. Breach Notification: Requirements and timeframes for reporting data breaches and security incidents
10. Audit Rights: Provisions for monitoring and verifying compliance with the addendum requirements
11. Term and Termination: Duration of the addendum and circumstances under which it can be terminated
12. Governing Law and Jurisdiction: Confirmation of Pakistani law as governing law and jurisdiction for disputes
1. Sub-processing: Terms for engaging sub-processors, to be included when the data importer may use third parties for processing
2. Special Categories of Data: Additional safeguards for sensitive personal data, required when transferring health, religious, or other sensitive information
3. Data Localization Requirements: Specific provisions for financial or other regulated data subject to State Bank of Pakistan requirements
4. Industry-Specific Compliance: Additional requirements for specific sectors like healthcare or financial services
5. Data Minimization and Retention: Specific provisions on data retention periods and minimization principles, when required by specific industry standards
6. Cross-Border Transfer Impact Assessment: Documentation of transfer impact assessment when transferring to countries without adequate protection levels
1. Schedule 1 - Description of Transfer: Detailed description of the data transfer including data categories, subjects, purposes, and frequency
2. Schedule 2 - Technical and Organizational Measures: Detailed security measures and controls implemented by both parties
3. Schedule 3 - Authorized Sub-processors: List of approved sub-processors and their roles, if applicable
4. Schedule 4 - Transfer Impact Assessment: Documentation of the assessment of risks and safeguards for the transfer
5. Appendix A - Data Processing Details: Specific details about processing activities, including systems used and data flows
6. Appendix B - Contact Points: List of key contacts for data protection matters at both organizations
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