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High Severity

Undefined Transfer Standards Create Business Paralysis

This provision requires businesses conducting large-scale data processing to complete Transfer Impact Assessments and obtain Authority approval before any cross-border data transfer, but fails to define what constitutes "compelling legitimate interests" or "effectiveness of security safeguards." Without clear approval criteria or decision timelines, businesses face operational uncertainty that prevents planning cloud migrations, regional data center operations, or multinational service delivery. The requirement to demonstrate subjective standards on a case-by-case basis creates compliance costs and delays that exceed international norms—GDPR provides adequacy decisions and standard contractual clauses as predictable pathways, while this provision requires individualized Authority approval regardless of destination country protections.