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High Severity

Approval Bottleneck Stifles Cloud Innovation

This provision requires Authority approval and Transfer Impact Assessments for all large-scale data transfers, creating significant barriers for digital services and cloud-based businesses. The requirement to demonstrate "effectiveness of security safeguards" and "compelling legitimate interests" lacks clear criteria or approval timelines, creating uncertainty that chills innovation. Unlike GDPR's adequacy framework, this requires case-by-case approval regardless of destination country protections, imposing disproportionate compliance costs on tech startups and digital service providers relying on cloud infrastructure.