Scenario
A European SaaS provider offering cloud-based document management across multiple EU and non-EU jurisdictions.
Challenge
Our client was notified by a national data protection authority (DPA) of a potential €1.8 million GDPR fine for unauthorized cross-border transfers of EU user data to a non-EU subcontractor in Southeast Asia. The DPA cited insufficient safeguards under GDPR and a lack of auditability around contractual and technical protections in place.
The client’s internal compliance and legal teams lacked real-time visibility into:
- What personal data categories were being transferred
- Which transfers required SCCs or transfer impact assessments (TIAs)
- Whether any safeguards were outdated or misapplied
Solution
Client integrated S8fe.ai to assess, document, and remediate compliance gaps in real time mostly through:
- Automated Labelling: Identified over 30 undocumented personal data elements.
- Risk Categorization: Labelled data across multiple jurisdictions to rank risk, sensitivity, and volume.
- Transfer Impact Intelligence: Flagged two jurisdictions as “high-risk” under GDPR standards, where additional supplementary measures were required.
- Remediation Dashboard: Generated ready-to-file evidence of transfer protocols, encryption safeguards, and updated contractual clauses.
Outcome
Based on the clarity, documentation, and demonstrable good faith efforts:
- Fine Reduced: From €1.8 million to €250,000
- Regulator Feedback: Cited “strong demonstrable remediation” and “exceptional transparency”
- Operational Result: No business interruption; international transfers continued with legal basis and confidence