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Intra Group Data Transfer Agreement
"I need an Intra Group Data Transfer Agreement under Nigerian law for transferring customer financial data between our Lagos-based parent company and three subsidiary companies in the banking sector, with implementation planned for March 2025."
1. Parties: Identification of the data exporter and data importer within the group, including registration details and addresses
2. Background: Context of the intra-group relationship and purpose of the data transfer agreement
3. Definitions: Key terms used throughout the agreement, including technical and legal terminology
4. Scope and Purpose: Detailed description of the data transfer activities covered by the agreement
5. Obligations of Data Exporter: Responsibilities and commitments of the entity sending the data, including data quality and legal basis for transfer
6. Obligations of Data Importer: Responsibilities and commitments of the entity receiving the data, including security measures and processing limitations
7. Data Security: Required security measures, protocols, and standards for protecting transferred data
8. Data Subject Rights: Procedures for handling data subject requests and ensuring their rights are protected
9. Breach Notification: Procedures and timeframes for reporting and handling data breaches
10. Audit Rights: Rights and procedures for conducting compliance audits
11. Duration and Termination: Term of the agreement, renewal provisions, and termination circumstances
12. Governing Law and Jurisdiction: Specification of Nigerian law as governing law and jurisdiction for disputes
13. General Provisions: Standard contractual clauses including severability, entire agreement, and amendments
1. Sub-processing: Include when data may be processed by additional group entities or third parties
2. Special Categories of Data: Include when sensitive personal data or special category data is being transferred
3. Cross-Border Transfers: Include when data will be transferred outside Nigeria
4. Industry-Specific Compliance: Include when transfers involve regulated industries (e.g., financial services, healthcare)
5. Disaster Recovery: Include when specific business continuity requirements exist
6. Cost Allocation: Include when there are specific charging arrangements between group entities
7. Intellectual Property Rights: Include when the transferred data involves proprietary information or IP
8. Local Data Protection Officer: Include when entities have designated DPOs that need to be referenced
1. Description of Transfer: Detailed information about the categories of data, purposes, and processing activities
2. Security Measures: Technical and organizational security measures implemented by both parties
3. Authorized Recipients: List of group entities and personnel authorized to access the transferred data
4. Sub-processors: List of approved sub-processors and their roles, if applicable
5. Data Subject Rights Procedure: Detailed procedures for handling data subject requests
6. Transfer Impact Assessment: Assessment of risks and safeguards for the data transfer
7. Breach Response Plan: Detailed procedures and contact information for breach response
8. Audit Framework: Detailed audit procedures, checklists, and requirements
Authors
Financial Services
Healthcare
Technology
Telecommunications
Manufacturing
Professional Services
Energy
Retail
Insurance
Education
Transportation and Logistics
Media and Entertainment
Legal
Compliance
Information Security
IT
Risk Management
Data Protection
Corporate Governance
Operations
Privacy
Information Governance
Regulatory Affairs
Chief Legal Officer
Data Protection Officer
Chief Privacy Officer
Legal Counsel
Compliance Manager
Information Security Manager
Chief Information Security Officer
Risk Manager
IT Director
Chief Technology Officer
Group Corporate Secretary
Head of Compliance
Privacy Manager
Information Governance Manager
Chief Operating Officer
Head of Legal
Corporate Counsel
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