International Data Transfer Disclosure

International Data Transfer Disclosure

International Data Transfer Disclosure

1. Overview of International Transfers

Status: Huma does not hold SecNumCloud 3.2 certification. However, we maintain hosting infrastructure primarily within the European Economic Area (EEA) and implement strict controls for any limited transfers outside the EEA.

As a health data processor certified under the French Health Data Host (HDS) framework, Huma is required to publicly disclose all arrangements for transferring personal health data (Données de Santé à Caractère Personnel - DSCPs) outside the European Economic Area.

This page provides:

  • A complete list of sub-processors and their data locations

  • Details of non-EEA access by third-country legislation

  • Risks associated with unauthorized access under third-country law

  • Supplementary safeguards implemented to mitigate those risks

  • Data subject rights and remedies

3. Transfer Details & Sub-Processor Information

Huma engages the following sub-processors who may access or process personal health data:


DocuSign (Electronic Signature Service)

Role

Sub-processor

Primary Data Location

Ireland (EU)

Parent Company Country

United States

Data Processing Activity

Prescription approval signatures, clinical document signing


Data Elements

Signer name, email address, signature timestamp, signed prescription PDF (encrypted, may include patient identifiers such as ID or initials). No direct health data is processed – documents are created and encrypted by Huma prior to DocuSign access.


Safeguards

  • TLS 1.2+ encryption in transit

  • AES-256 encryption at rest in DocuSign EU data centres

  • Standard Contractual Clauses with supplementary safeguards

  • No onward transfers outside the EEA


Intercom (Customer Communication & Support)

Role

Sub-processor

Primary Data Location

Ireland (EU)

Parent Company Country

United States

Data Processing Activity

In-app messaging, support communications, user feedback


Data Elements

Limited to user contact details, message metadata, interaction logs (cookies, IP addresses), and feedback. No health data or patient message content is transferred – clinical messages remain within Huma's secure environment.


Safeguards

  • Primary processing in Ireland (EEA)

  • Standard Contractual Clauses (2021/914/EU) for any US access

  • End-to-end encryption where available

  • Strict access controls and audit trails

  • Data Processing Agreement with Sub-Processor Addendum


Twilio (Secure Communications Infrastructure)

Role

Sub-processor

Primary Data Locations

Ireland & Germany (EU)

Parent Company Country

United States

Data Processing Activity

Message delivery metadata, contact details, communication routing


Data Elements

Limited to phone numbers, email addresses, and message delivery metadata required for routing. No message content or health data is transferred.


Safeguards

  • Primary processing in EU data centres (Ireland, Germany)

  • Twilio Binding Corporate Rules (BCRs) for intra-group transfers

  • Standard Contractual Clauses (2021/914/EU) for US access

  • UK International Data Transfer Addendum (IDTA) for UK data

  • Supplementary technical and organizational measures

4. Risk Assessment – Requirement 30

As required by HDS Requirement 30, we identify and assess the risks of unauthorized access to DSCPs under third-country legislation:

HIGH LEGISLATIVE RISK

US CLOUD Act & FISA Amendments

Applicable to: DocuSign, Intercom, Twilio (all US parent companies)

Description: The US Clarifying Lawful Overseas Use of Data (CLOUD) Act allows US federal authorities to compel US companies (and foreign subsidiaries under US control) to disclose stored data without a foreign warrant. FISA Amendments Section 702 allows warrantless collection of foreign communications.

Potential Unauthorized Access: US law enforcement, intelligence agencies (NSA, FBI, CIA, DHS) may demand access to personal data for national security purposes without European judicial oversight or data subject notification.

Residual Risk Level: Medium-High – While primary processing occurs in the EU, limited support/routing operations in the US create exposure risk.

MEDIUM LEGISLATIVE RISK

Absence of Adequate Data Protection Framework

Applicable to: All US-based processors

Description: The US does not have a comprehensive federal data protection law equivalent to the GDPR. Data protection is fragmented across sector-specific laws (HIPAA, HITECH, COPPA) with significant gaps.

Potential Unauthorized Access: US companies have broad discretion in data use, monetization, and third-party sharing absent contractual restrictions. Less stringent oversight of data handling practices.

Residual Risk Level: Low-Medium – Mitigated by SCCs, DPAs, and contractual restrictions limiting data use to processing activities only.

LOW LEGISLATIVE RISK

Commercial Data Broker Market

Applicable to: All US processors

Description: The US data broker market allows third parties to purchase personal data from companies, subject to limited restrictions.

Potential Unauthorized Access: Unlikely in healthcare context due to HIPAA restrictions on Huma's processors; however, data outside HIPAA scope (user contact details, IP addresses) could theoretically be sold.

Residual Risk Level: Low – Substantially mitigated by contractual prohibitions on secondary use and data broker sales.


Summary of Non-European Regulations Requiring Access Disclosure

Regulation

Country

Scope

Risk to DSCPs

Mitigation

CLOUD Act (2018)

USA

Compelled disclosure by federal authorities

High – Direct access demand without EU judicial review

SCCs, DPA, UK IDTA; limited US processing; EU data residency

FISA § 702

USA

Warrantless collection for national security

High – Intelligence agency access without warrant

SCCs, supplementary safeguards, minimal US access

Federal Rules of Evidence / Discovery

USA

Civil litigation disclosure

Low – Limited to specific disputes; subject to protective orders

Contractual dispute resolution; limited scope

Absence of GDPR Equivalent

USA

Data use and retention discretion

Medium – Broad corporate discretion in data handling

Contractual DPA; processing limitations; no secondary use

5. Data Protection Safeguards

Huma implements multiple layers of safeguards to ensure the level of data protection guaranteed by GDPR is not undermined, in line with the EDPB's Recommendations 01/2020 (post-Schrems II):

Technical Safeguards

  • Data Minimization: Only essential personal data is transferred to sub-processors; health data remains within Huma's EEA infrastructure

  • Encryption in Transit: All transfers use TLS 1.2+ minimum; sensitive documents encrypted end-to-end

  • Encryption at Rest: AES-256 encryption for data stored in sub-processor systems

  • Pseudonymization: Where applicable, data is pseudonymized before transfer to limit re-identification risk

  • Access Controls: Role-based access control (RBAC) and principle of least privilege; audit logging of all data access

  • Network Segmentation: Health data processing segregated from general platform infrastructure

  • Data Location Controls: Primary processing geographically restricted to EEA data centres; limited exceptions documented and monitored

Contractual Safeguards

  • Standard Contractual Clauses (SCCs): All non-EEA transfers governed by European Commission-approved SCCs (Decision 2021/914/EU)

  • UK International Data Transfer Addendum (IDTA): For UK-originating data, transfers to non-UK/EEA entities governed by the UK IDTA (in addition to SCCs)

  • Binding Corporate Rules (BCRs): Twilio's BCRs provide EDPB-approved framework for intra-group transfers

  • Data Processing Agreements (DPAs): All sub-processors bound by DPA incorporating GDPR Article 28 and GDPR Chapter V requirements

  • Supplementary Measures Addendum: Explicit contractual commitments to implement EDPB Recommendations 01/2020

  • Limitation on Processing: Contractual prohibition on secondary use, data broker sales, or transfer to third parties without Huma's written consent

  • Sub-processor Chains: No sub-processor may engage further sub-processors without prior written approval by data controller and Huma

Organizational Safeguards

  • Data Protection Impact Assessments (DPIAs): Comprehensive DPIA conducted for each transfer arrangement; periodic review and update

  • Sub-processor Due Diligence: Annual security assessments and SOC 2 Type II audits (or equivalent) of sub-processors

  • Incident Response Plan: Documented procedures for breach notification, containment, and remediation within 72 hours per GDPR Article 33

  • Data Subject Rights Processes: Mechanisms to fulfill access, rectification, erasure, and portability requests within legal timeframes

  • Privacy Training: Annual GDPR and HDS compliance training for all staff handling personal data

  • Regulatory Cooperation: Commitment to cooperate with CNIL, DPA, and other data protection authorities on investigations and audits

  • Monitoring & Audit: Quarterly compliance monitoring; annual third-party audit of transfer arrangements

Recourse & Remedies

  • Legal Recourse in EU: Data subjects may lodge complaints with their national data protection authority (CNIL for France)

  • Right to Judicial Remedy: Data subjects may pursue judicial remedies in EU/EEA courts against unauthorized access under Article 79 GDPR

  • Contractual Indemnification: Huma contractually indemnifies customers against fines and damages arising from sub-processor breaches

  • Escalation Procedure: Data subjects may escalate concerns to Huma's Data Protection Officer (DPO) for investigation and remedy

6. Complete Transfer Matrix (Requirement 31)

The following table provides a comprehensive overview of all data transfer arrangements:

Sub-Processor

Data Processing Activity

Data Origin (From)

Primary Location (To)

Non-EEA Access

Legal Basis

Risk Level

Safeguards

DocuSign

Prescription document signature & approval

France, Portugal, Czech Republic, Sweden, UK

Ireland (EU)

No – data remains in EU

GDPR Article 46 (SCCs)

Low

TLS 1.2+, AES-256, SCCs, no onward transfer

Intercom

In-app messaging, support communications

France, Portugal, Czech Republic, Sweden, UK

Ireland (EU) / Limited US

Yes – US limited support access

GDPR Article 46 (SCCs + supplementary measures)

Medium

SCCs, DPA, UK IDTA, access controls, audit logs, minimal US processing

Twilio

Message delivery, communication routing

France, Portugal, Czech Republic, Sweden, UK

Ireland & Germany (EU) / Limited US

Yes – US support & routing access

GDPR Article 46 (SCCs + BCRs + supplementary measures)

Medium

SCCs, BCRs, UK IDTA, DPA, encryption, strict access controls, audit monitoring

Key Finding: Primary storage and processing of health data (DSCPs) occurs exclusively within the EEA (UK and EU data centres). Limited non-EEA access is restricted to metadata, support operations, and communication routing – never clinical content. All transfers protected by European Commission-approved Standard Contractual Clauses and supplementary technical/organizational safeguards.

7. Data Subject Rights & Remedies

Under GDPR and HDS certification, data subjects (patients) retain full rights regarding their personal health data:

GDPR Data Subject Rights

  • Right to Access (Article 15): Request a copy of your personal data held by Huma

  • Right to Rectification (Article 16): Correct inaccurate or incomplete personal data

  • Right to Erasure (Article 17): Request deletion of your data ("right to be forgotten")

  • Right to Restriction (Article 18): Restrict processing of your data pending dispute resolution

  • Right to Portability (Article 20): Receive your data in a structured, portable format

  • Right to Object (Article 21): Object to processing for legitimate interests

  • Rights Related to Automated Decision-Making (Article 22): Not be subject to decisions based solely on automated processing


How to Exercise Your Rights

To exercise any of the above rights, submit a written request to:

Huma Data Protection Officer (DPO)
Email: dpo@huma.ai
Address: Huma Ltd , 13th Floor, Millbank Tower, 21-24 Millbank, London, SW1P 4QP, United Kingdom.
Response time: 30 calendar days (extendable to 60 days for complex requests)


Right to Lodge a Complaint

If you believe your rights have been violated, you have the right to lodge a complaint with your national data protection authority:

For France:
Commission Nationale de l'Informatique et des Libertés (CNIL)
Phone: +33 1 53 73 22 22
Online complaint form


Right to Judicial Remedy

You may seek judicial remedies in the courts of your country of residence for damages arising from unlawful processing or unauthorized access. Huma provides contractual indemnification for damages resulting from sub-processor breaches.


Right to Be Informed About Data Transfers

This page serves as your notice of international data transfers. Huma commits to:

  • Maintain transparency about all sub-processor arrangements

  • Update this disclosure within 30 days of any material change (new processor, change of location, change of safeguards)

  • Notify data subjects of any data breach involving non-EEA access within 72 hours per GDPR Article 33

  • Cooperate with data protection authorities on investigations


Important Notice

This disclosure is provided in compliance with HDS Requirement 31 (Article R1111-15 of the French Code de la Santé Publique) and GDPR Chapter V. It reflects Huma's commitment to transparency and data protection in the processing of personal health data.

Assessment of Adequacy: While Huma does not hold SecNumCloud 3.2 certification, we maintain equivalent data protection through:

  • Primary EEA data residency for all health data

  • European Commission-approved Standard Contractual Clauses (2021/914/EU)

  • EDPB Recommendations 01/2020 supplementary safeguards

  • Comprehensive technical, contractual, and organizational controls

  • Regular third-party security audits (SOC 2 Type II)

Regulatory Authority: For inquiries regarding this disclosure or Huma's HDS compliance, contact the CNIL or your local data protection authority.

Last Updated: March 20, 2026

Version: 1.0 – HDS Compliance Edition

This page is reviewed and updated quarterly, or upon material change to data transfer arrangements.