Fastly · Fastly Privacy Policy · View original document ↗

Cross-Border Data Transfers via Standard Contractual Clauses

Medium severity Medium confidence Explicitdocumentlanguage Rare · 2 of 325 platforms
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Document Record

What it is

When Fastly moves personal data from the EU, UK, or Switzerland to other countries (such as the US), it uses Standard Contractual Clauses, which are pre-approved legal contracts designed to ensure data protection standards follow the data. This is the primary legal mechanism Fastly uses to authorize international data transfers.

This analysis describes what Fastly'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Cross-border transfer mechanisms are a significant area of GDPR enforcement, and the adequacy of Standard Contractual Clauses depends on whether the destination country provides essentially equivalent protection. Organizations relying on SCCs may also need to conduct Transfer Impact Assessments.

Interpretive note: The policy does not specify which SCC module applies to each transfer relationship, nor whether Fastly participates in the EU-US Data Privacy Framework, creating some ambiguity for enterprise customers conducting transfer impact assessments.

Consumer impact (what this means for users)

Your personal data may be transferred from the EU, UK, or Switzerland to Fastly's servers or sub-processors in other countries, including the US. Fastly states it uses Standard Contractual Clauses to provide a legal basis for this transfer, though the practical protection this affords depends on implementation and the specific countries involved.

How other platforms handle this

Figma Medium

When we transfer personal information from the European Economic Area, United Kingdom, or Switzerland to countries that have not been found to provide an adequate level of protection under applicable law, we take steps to provide appropriate safeguards, including through the use of Standard Contract...

Upwork Medium

When we transfer personal data outside the European Economic Area, United Kingdom, or Switzerland, we use appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your data is protected.

Canva Medium

Canva is headquartered in Australia and has operations and service providers in a number of countries. When we transfer personal information outside of the country in which it was collected, we take steps to ensure that appropriate safeguards are in place to protect your information, including the u...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we transfer your personal data to countries outside of these regions only where we have put in place appropriate safeguards, such as the use of Standard Contractual Clauses approved by the European Commission.

— Excerpt from Fastly's Fastly Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V, which governs international data transfers, and the European Commission's 2021 updated Standard Contractual Clauses. The UK's International Data Transfer Agreement (IDTA) applies for UK-to-third-country transfers. The EU-US Data Privacy Framework may also be relevant if Fastly participates in it, though the policy references SCCs as the primary mechanism. EU data protection authorities have enforcement authority. (2) GOVERNANCE EXPOSURE: Medium. SCCs are a recognized transfer mechanism under GDPR, but their use requires a documented Transfer Impact Assessment (TIA) where the destination country's legal framework may undermine the SCCs' effectiveness (as established by the CJEU in Schrems II). Fastly's policy does not describe whether TIAs are conducted, which is a compliance gap for enterprise customers who must document their own data flows. (3) JURISDICTION FLAGS: EU/EEA and UK data subjects are the primary affected population. Switzerland has its own transfer requirements under the revised Federal Act on Data Protection (revFADP). Enterprise customers in regulated sectors (financial services, healthcare) face heightened scrutiny of international transfer mechanisms from sector-specific regulators. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should request copies of Fastly's executed SCCs and verify that they use the updated 2021 European Commission modules appropriate to the controller-processor relationship. DPA terms should specify which SCC module applies and identify the specific sub-processors and countries involved in data transfers. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should update their Records of Processing Activities (RoPA) to reflect Fastly as a data processor and international data transfer destination. A TIA should be documented for transfers to the US or other countries without an EU adequacy decision. Legal teams should verify whether the EU-US Data Privacy Framework offers a simpler transfer basis if Fastly is certified under that framework.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Fastly Privacy Policy
Entity
Fastly
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010404
Document ID
CA-D-00676
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
cbddaed40180df2ad9f739ec146b4892475952ea75220d4fd8a1912da0062603
Analysis generated
May 8, 2026 15:45 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Fastly
Document: Fastly Privacy Policy
Record ID: CA-P-010404
Captured: 2026-05-08 15:45:23 UTC
SHA-256: cbddaed40180df2a…
URL: https://conductatlas.com/platform/fastly/fastly-privacy-policy/cross-border-data-transfers-via-standard-contractual-clauses/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Fastly's Cross-Border Data Transfers via Standard Contractual Clauses clause do?

Cross-border transfer mechanisms are a significant area of GDPR enforcement, and the adequacy of Standard Contractual Clauses depends on whether the destination country provides essentially equivalent protection. Organizations relying on SCCs may also need to conduct Transfer Impact Assessments.

How does this clause affect you?

Your personal data may be transferred from the EU, UK, or Switzerland to Fastly's servers or sub-processors in other countries, including the US. Fastly states it uses Standard Contractual Clauses to provide a legal basis for this transfer, though the practical protection this affords depends on implementation and the specific countries involved.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.

Is ConductAtlas affiliated with Fastly?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Fastly.