Which of the following are not mandatory pre-requisite before transferring sensitive personal data to its Asian branches?

A multinational company with operations in several parts within EU and outside EU, involves international data transfer of both its employees and customers. In some of its EU branches, which are relatively larger in size, the organization has a works council. Most of the data transferred is personal, and some of the data that the organization collects is sensitive in nature, the processing of some of which is also outsourced to its branches in Asian countries.

Which of the following are not mandatory pre-requisite before transferring sensitive personal data to its Asian branches?
A . Notifying the data subject
B . Conducting risk assessment for the processing involved
C . Determining adequacy status of the country
D . Self-certifying to Safe Harbor practices and reporting to Federal Trade Commission

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Answer: D