Atlassian transfers personal data internationally and states it uses Standard Contractual Clauses approved by EU and UK regulators to provide a legal basis for those transfers when data moves outside of Europe.
This analysis describes what Atlassian's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The policy states that personal data from EU and UK users may be transferred internationally and that Standard Contractual Clauses are the stated mechanism, which matters because the adequacy of these mechanisms for transfers to certain jurisdictions may require ongoing assessment under post-Schrems II guidance.
Interpretive note: The specific adequacy of Atlassian's SCCs and supplementary measures for transfers to particular jurisdictions cannot be confirmed from the policy text alone and depends on Atlassian's DPA documentation and the specific destination country.
Personal data of EU and UK users may be transferred to Atlassian entities or service providers in other countries, including the United States, under Standard Contractual Clauses. EU and UK users can request information about the specific safeguards in place for their data by contacting Atlassian's privacy team.
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"Atlassian may transfer your personal information to countries other than the country where you initially provided it. When we transfer personal information outside of the EEA or the UK, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office.— Excerpt from Atlassian's Atlassian Privacy Policy
(1) REGULATORY LANDSCAPE: GDPR Chapter V and UK GDPR equivalent provisions govern international data transfers and require appropriate safeguards. Standard Contractual Clauses must comply with the updated 2021 EU SCCs. The CJEU's Schrems II decision requires supplementary measures when transferring to jurisdictions where government access to data may impair SCC protections. The European Data Protection Board and UK ICO are the relevant enforcement authorities. (2) GOVERNANCE EXPOSURE: Medium. Organizations relying on Atlassian's SCCs for their own GDPR compliance must confirm that Atlassian's SCCs are the correct module for the controller-processor relationship and that supplementary measures are documented where required. (3) JURISDICTION FLAGS: EEA and UK organizations have heightened exposure. Transfers to the United States must be assessed following the EU-US Data Privacy Framework; organizations should confirm whether Atlassian is certified under that framework. Swiss organizations should assess adequacy under Switzerland's revised Federal Act on Data Protection. (4) CONTRACT AND VENDOR IMPLICATIONS: The DPA should reference the applicable SCCs module (Module 2 for controller-to-processor transfers) and include supplementary measures documentation. Procurement teams should request Atlassian's Transfer Impact Assessment or equivalent documentation if required by their DPA counterparts. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm Atlassian's current DPA references the 2021 updated SCCs, review the sub-processor list for recipients in non-adequate countries, and maintain documentation of transfer safeguards in Article 30 records.
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The policy states that personal data from EU and UK users may be transferred internationally and that Standard Contractual Clauses are the stated mechanism, which matters because the adequacy of these mechanisms for transfers to certain jurisdictions may require ongoing assessment under post-Schrems II guidance.
Personal data of EU and UK users may be transferred to Atlassian entities or service providers in other countries, including the United States, under Standard Contractual Clauses. EU and UK users can request information about the specific safeguards in place for their data by contacting Atlassian's privacy team.
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