Live — in production Transfer Impact Assessments · PDPA s.129

Every overseas transfer now needs its own basis. Assess it, evidence it and sign it — in one place.

The whitelist is gone. Praxis Frontier walks each transfer through the eight s.129 conditions, compares the destination against a 21-provision Malaysian floor across 129 jurisdictions, attaches hashed evidence and produces a regulator-ready Transfer Impact Assessment with a three-year validity clock. The tool suggests. A qualified person decides and signs.

One complete run free · company email, no card 129 jurisdictions pre-scored on the Malaysian floor Issued reports are immutable and reproducible
129destination jurisdictions pre-scored
21provisions in the Malaysian-floor matrix
8s.129 conditions, worked through every time
3 yearsvalidity clock on every issued TIA
The problem

A transfer memo is an opinion. A challenged transfer needs a record.

One-word adequacy

“Adequate” or “not adequate” tells a regulator nothing about which provisions you compared, which dataset version you used or why you concluded what you did.

Reasoning scattered across email

Three years on, the vendor has changed, the law has changed and the associate has left. The basis for the transfer is wherever the thread ended.

Assessments that quietly expire

A TIA that was sound when issued is not sound forever. Without a validity clock and a revision chain, nobody notices until someone asks.

What you get

A defensible basis for every transfer — and the proof of it.

Structured, evidenced, signed

A firm assesses transfer risk in a guided, evidenced workflow instead of an ad hoc memo — the tool suggests, a qualified human signs off.

Citation-backed report and audit pack

A regulator-ready PDF and a Commissioner-ready audit pack per client reduce your exposure if a transfer decision is later challenged.

Nothing expires unnoticed

A three-year validity clock on every issued TIA and clone-based revisions mean a firm never loses track of an expiring assessment.

Reproducible after the world changes

Each assessment freezes the jurisdiction dataset it relied on, so an issued report stays reproducible after the data is updated.

Chain of custody for evidence

SHA-256 hashing on every upload gives a defensible chain of custody for the documents that support the finding.

Many clients, one deployment

Firm-scoped multi-tenancy lets one workspace serve many client matters with no cross-contamination between them.

How it works

From client matter to superseding report.

Each stage is structured so the reasoning, the evidence and the decision stay connected three years later, when someone asks why.

01
Create the matter

Organisation → Client → Matter → Assessment. Every query is scoped to your firm; every event lands on a hash-chain-anchored timeline.

02
Capture the transfer

Controller, overseas receiver, destination, data categories, purpose, safeguards and material circumstances — structured fields, not a blank memo.

03
Classify the destination

129 jurisdictions pre-scored against the 21-provision Malaysian-floor matrix, with four essential-guarantee gates that can fail a destination regardless of its average.

04
Establish the legal basis

All eight s.129 conditions, Route A or Route B mapping, and the necessity test.

05
Attach the evidence

Uploads to the Evidence Vault are SHA-256 hashed, slotted by evidence type and attached to the finding they substantiate. Disposal dates are surfaced, never auto-applied.

06
Review, sign, issue — and revise without overwriting

Qualified-person approval, then a regulator-ready PDF. Drafts are watermarked; issued assessments are immutable, carry a three-year clock and revise by clone.

What is inside

Everything the s.129 test asks for, in the order it asks.

129 jurisdictions, one matrix

Every destination scored on the same 21 Malaysian-floor provisions with four essential-guarantee gates — a provision-by-provision picture, not a label.

All eight s.129 conditions

Work through every condition, map to Route A or Route B, and run the necessity test with the reasoning recorded.

Evidence Vault

SHA-256-hashed uploads (25 MB each), slotted by evidence type; disposal dates surfaced, never auto-deleted.

Regulator-ready PDF

Draft watermarking, a three-year validity clock and a version/clone revision chain on every issued report.

Audit pack per client

One self-contained document: the full transfer and assessment register, legal bases, evidence inventory and audit-chain verification — produced on demand.

“Explain why”

Open the comparison, source provision, dataset version and rationale behind any material finding — and record a reasoned departure if you disagree.

Matter hierarchy

Organisation → Client → Matter → Assessment, with a hash-chain-anchored timeline for every matter.

Immutable assessments

Completed assessments cannot be edited; revisions clone, supersede and keep a frozen per-assessment dataset snapshot.

Per-firm audit chain

Append-only, hash-chained audit log with an integrity-verification endpoint an auditor can call.

Built to be defended

Built for the day someone asks why.

Route A — destination comparison
Provision-by-provision comparison of the destination's law against the Malaysian floor: findings, the four essential-guarantee gates, supporting provisions and unresolved gaps.
Route B — safeguards & basis
Documentation of the specific safeguards, enforceable obligations and s.129 condition relied upon, with the hashed evidence attached.
Access
Firm-scoped multi-tenancy on every query; cookie-bound sessions with argon2id password hashing; firm registration approved by an administrator.
Validity & revision
A three-year clock on every issued TIA. A superseding version can be issued after a material change without overwriting the original.
Handoff from Praxis DPIA
When a DPIA's Evaluate stage finds a cross-border transfer, it opens a TIA here with the facts and evidence carried across. The finding returns to the DPIA record.
Praxis Integrity
Every issued TIA is listed for life in the suite's public verification registry as it ships, so a counterparty can confirm it is genuine and current.

Who runs it

Law firms

Client-segregated matters, a hashed Evidence Vault, reasoned departures on record and a Commissioner-ready audit pack per client — the transfer memo replaced by a structured, evidenced workflow.

Enterprise DPOs

A group's shared HR platform, CRM or cloud vendor assessed once, properly, with a three-year validity clock and clone-based revisions when the vendor or the law changes.

E-commerce, hotels & rentals

An overseas fulfilment partner, a foreign booking platform or a property-management system hosted abroad — each needs an s.129 basis, and Frontier walks you through it.

How to get it

Start free. Pay per assessment or subscribe.

Every new organisation gets one complete transfer assessment free — the full workflow and the issued report. After that, buy one at a time or take a suite plan. All prices in MYR, exclusive of applicable tax.

Free first run
RM0one complete transfer assessment

The full s.129 workflow and the issued report for one client. Company email required; no card needed.

Start free
Pay per assessment
RM950one TIA · 30-day window

One clean issued report, listed in Praxis Integrity. One free 30-day extension on request. Credited against your first subscription if you subscribe within 90 days.

Buy one transfer assessment
Suite plan
from RM599per month · 3 client workspaces

Praxis Frontier plus every other Praxis application, licensed by active client matter. Unlimited users, unlimited archiving, slots free on archive.

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Common questions

Before you commit.

No. It structures the s.129 analysis, scores the destination against the Malaysian floor and assembles the evidence. The applicable route and the conclusion are determined by the reviewing professional, who signs the assessment.

Each destination has been scored on the same 21 provisions of the Malaysian floor, with four essential-guarantee gates. When you select a destination you see the provision-by-provision picture — and each issued assessment freezes the dataset version it relied on.

One self-contained document per client: the transfer and assessment register, legal bases, evidence inventory and a verification of the hash-chained audit log — produced on demand rather than reconstructed from email.

When a DPIA's Evaluate stage finds a cross-border transfer, Praxis DPIA opens a TIA here with the facts and evidence carried across. The finding returns to the DPIA record.

Transfer assessments do not stay valid indefinitely. Frontier tracks validity on every issued TIA so a firm never loses track of an expiring assessment, and issues a superseding version when circumstances change.

No. Praxis Frontier structures and evidences professional analysis. Outputs require review and approval by an appropriately qualified person before reliance or issue.

Praxis Frontier structures and evidences professional analysis. It does not provide legal advice, and it does not replace the review and approval of an appropriately qualified person before reliance or issue.

PDPA Act 709 (Act A1727 amendments)s.129 cross-border · CBPDT guidance21-provision Malaysian floor · 129 jurisdictions
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A client transfer, a group's shared platform, or an online store's overseas fulfilment partner.

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