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Transfers of data outside the European Economic Area
This document is subject to an annual review, which checks that the existing measures match the expectations / needs / constraints of the company.
Version
Date
Author
Nature of the change
0.01
18/06/25
FDR (CISO)
Document created
1
02/06/25
Management
Approval
In accordance with requirements 29 and 30 of the ANS HDS standard, Synovo Group publishes the mapping of any access to, or transfer of, personal health data to countries outside the European Economic Area (EEA), together with the associated risks.
The actor's registered name
Role within the hosting service (Host / subcontractor of the Host)
HDS certified (yes / no / exempt)
SecNumCloud 3.2 qualified
Hosting activity the actor takes part in
Access to personal health data from countries outside the European Economic Area, by the Host or one of its subcontractors (requirement no. 29 of the HDS standard)
Host or subcontractor exposed to a risk of access to personal health data from countries outside the European Economic Area, imposed by a third country's legislation in breach of Union law (requirement no. 30 of the HDS standard)
Madixy
Subcontractor of the Host
No (exempt, not a host)
No
Customer support (remote access to health data)
Yes, access from Madagascar
► covered by no adequacy decision
No risk identified to date in connection with Malagasy legislation equivalent to Article 48 of the GDPR; residual risk mitigated by encryption, absence of storage, access over VPN, strict access control and standard contractual clauses (SCC 2021/914/EU)
