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Checklist · Internal
Transfer Risk Assessment Checklist for Accountants
Steps to consider before personal data leaves the UK to an outsourcing provider.
Built by a practising Chartered Accountant · Unlimited users · 60-day free trial · Last updated 24 September 2026
Quick answer
General guidance, not legal advice. Take advice on your contracts and data transfers. A transfer risk assessment (TRA) helps you consider whether it's appropriate to transfer client personal data to a provider outside the UK, and what safeguards are needed. This checklist is a general prompt only — take legal advice and refer to current ICO guidance before relying on it.
Why complete a transfer risk assessment?
Where personal data is transferred outside the UK, UK GDPR generally requires a valid transfer mechanism, and depending on the destination country and circumstances, a transfer risk assessment to check that mechanism will offer adequate protection in practice.
This is a specialist area of data protection law; this checklist is only a prompt to help you organise the assessment, not a substitute for it.
What should the assessment consider?
Consider the destination country's laws, the type of data being transferred, the safeguard being relied on (such as the ICO's IDTA or UK Addendum), and whether additional measures are needed.
Areas to work through
- Destination country and whether it has UK adequacy status [VERIFY current status]
- Type and sensitivity of the personal data being transferred
- Legal safeguard being relied on (e.g. IDTA, UK Addendum)
+ 2 more in the full download
Checklist preview
0/4 done · showing 4 of 12 itemsThe full 12-item checklist is in the download below. Enter your name and email to get it as a Word or PDF file.
This is a standard checklist. Each firm's requirements may vary, so please cross-check everything against current GOV.UK, Companies House and professional body guidance before relying on it.
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Save each group as a task with subtasks, attach it to the right service and let recurring tasks create it for every client, every period. Each item gets an owner and a deadline, and nothing depends on someone remembering to print the list. See task and subtask templates.
What are the common mistakes?
- Transferring data before completing any risk assessment
- Assuming a signed contract alone is sufficient without considering local laws
- Not documenting the assessment or its conclusion
- Failing to review the assessment when circumstances change (e.g. new sub-processor or country)
“Automation saves time and no follow-up is missed.”
Frequently asked questions
Do I need a transfer risk assessment for every provider?
It's generally needed where personal data is transferred outside the UK using mechanisms like the IDTA or UK Addendum. [VERIFY] your specific obligations with a data protection adviser.
What is the ICO IDTA?
The International Data Transfer Agreement is one of the ICO's approved transfer mechanisms; the UK Addendum is used alongside the EU Standard Contractual Clauses as an alternative. [VERIFY] which is appropriate for your transfer.
Who should carry out the assessment?
Ideally someone with data protection expertise; get legal review before relying on the conclusion, particularly for higher-risk transfers.
What if the destination country changes its laws?
This is exactly why assessments should be reviewed periodically and not treated as a one-off exercise.
Does this replace the data processing agreement?
No, the transfer risk assessment works alongside the DPA and any transfer mechanism; it doesn't replace either.
Does Remindoo carry out transfer risk assessments for me?
No, Remindoo does not provide legal or data protection assessments; this checklist is a general organisational aid only.
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Sources
Last updated 24 September 2026. General guidance, not regulatory advice.
Why recording AML checks properly matters
UK accountants must follow the Money Laundering Regulations and their supervisor's guidance. If a check is not recorded, supervisors will generally treat it as not done.
Evidence for your supervisor
Dated ID checks and risk assessments on each client file are what a supervisor asks to see during a review.
Consistent risk scoring
A standard risk assessment means every client is judged the same way, whoever onboarded them.
Ongoing monitoring
Reminders for periodic reviews help keep checks current rather than done once and forgotten.
Faster onboarding
Built-in digital ID and AML checks in Remindoo reduce back-and-forth with new clients.
Practical tips from UK practice
- Complete identity checks and a risk assessment before starting chargeable work.
- Set review dates by risk level, with higher-risk clients reviewed more often.
- Record the reason for each risk rating, not just the rating.
- Check your supervisor's current guidance, as requirements can change.
Related Remindoo features
Written and reviewed by Waqas Sagar ACA FCCA FMAAT, Chartered Accountant with 18+ years in practice. Founder and MD of Accotax, an ICAEW, ACCA and AAT regulated London practice that has served over 5,000 clients, and founder of Remindoo. Guidance is general; check current GOV.UK and professional body guidance for your firm.
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