iCloud and GDPR: hosting, non-EU transfer and DPA

iCloud is published by Apple Distribution International Ltd. If your teams use it, it is a processor within the meaning of Article 28 GDPR and it must appear in your record of processing activities.

Does using iCloud mean a non-EU transfer?

Yes. The transfer relies on Standard Contractual Clauses. You must keep the signed SCC and, in principle, a transfer impact assessment.

What to write in your Article 30 record

Purpose: File storage. Categories of personal data: identity, content. Recipient: Apple Distribution International Ltd. Transfer: Standard contractual clauses. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects iCloud from the domain name of the tab — never from page content — and pre-fills the record above in one click. The extension flags the record if the transfer mechanism is missing or unverified.

Indicative information from public sources. The transfer mechanism actually applicable to you is the one written in your contract.