Fact is for most companies that they are already transmitting data internationally, because they use the Internet (for example, to email spreadsheets to various office locations), or because they have subsidiaries, customers, suppliers or channel partners in other jurisdictions. In most cases, data transfers occur because data is needed in different jurisdictions, not because of where the data is stored. With respect to employee data in a global human resources information system, for example, companies need to cause personal data to be transferred across borders to populate the system – whether they host it themselves or engage a cloud computing service provider.
