The document states that Twilio has conducted Transfer Impact Assessments for each sub-processor engagement that involves transferring personal data across national borders, asserting compliance with cross-border transfer obligations under applicable data protection law.
This analysis describes what Twilio'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
This provision asserts that Twilio has fulfilled a key accountability obligation under GDPR Chapter V and associated guidance from the European Data Protection Board regarding international data transfers, which is directly relevant to EU and UK customers' own accountability documentation.
The agreement states that Transfer Impact Assessments have been performed for cross-border sub-processor transfers; customers subject to GDPR or UK GDPR should assess whether Twilio's assessments are accessible for their own accountability records and whether they cover all relevant processing locations listed in the sub-processor table.
Cross-platform context
See how other platforms handle Transfer Impact Assessments for Cross-Border Sub-Processor Transfers and similar clauses.
Compare across platforms →"Where the engagement of a sub-processor requires the cross-border transfer of personal data, Twilio has performed Transfer Impact Assessments for such data transfer.Excerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (Articles 44-49) governing transfers of personal data to third countries, and the European Data Protection Board's recommendations on supplementary measures for international transfers.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision asserts that Twilio has fulfilled a key accountability obligation under GDPR Chapter V and associated guidance from the European Data Protection Board regarding international data transfers, which is directly relevant to EU and UK customers' own accountability documentation.
The agreement states that Transfer Impact Assessments have been performed for cross-border sub-processor transfers; customers subject to GDPR or UK GDPR should assess whether Twilio's assessments are accessible for their own accountability records and whether they cover all relevant processing locations listed in the sub-processor table.
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