Dekimu · anchored receipts docs
ATR — Anchored Transfer Receipts
Cryptographic proof of a cross-border data transfer — arrangement, per-transfer record, transfer impact assessment, or suspension.
Purpose
An ATR records the cross-border transfer lifecycle: the legal arrangement under which transfers occur (SCCs, BCRs, adequacy decision, etc.), each individual transfer event, any Transfer Impact Assessment (TIA) conducted following the Schrems II ruling, and any suspension of transfers.
An arrangement receipt is typically created once per transfer mechanism and referenced by subsequent individual transfer receipts via the envelope's prev chain field.
Event types
| Kind | Label | Description |
|---|---|---|
arrangement | Arrangement | Transfer mechanism established. |
transfer | Transfer | Data actually transferred. |
tia | Transfer Impact Assessment | Supplementary measures evaluated. |
suspension | Suspension | Transfer halted. |
Key fields
transfer_mechanism — the legal basis for the transfer: adequacy decision, standard contractual clauses, binding corporate rules, derogation (Art. 49), or other safeguard.
destination_country — ISO 3166-1 alpha-2 country code of the data-importing country. For cloud providers, the region where data will be stored or processed.
adequacy_decision — reference to the applicable European Commission adequacy decision, if the transfer relies on one. Includes decision date and any sectoral scope restrictions.
Regulatory context
GDPR Chapter V (Arts. 44–49) governs transfers of personal data to third countries or international organisations. Following the Court of Justice's Schrems II ruling (C-311/18), transfers relying on SCCs require a Transfer Impact Assessment to verify that the destination country's laws do not undermine the protections offered by the SCCs. The ATR TIA event documents this assessment, including the supplementary technical, contractual, or organisational measures adopted.