Getting it into your agent
One page per mod, every tool's command on it. A separate URL per tool would split the same page into five that compete with each other.
npx skills add mukul975/Privacy-Data-Protection-Skills --skill art49-derogationsgit clone --depth 1 https://github.com/mukul975/Privacy-Data-Protection-SkillsWrote this? Show the measurements
A badge with what this costs and how it scanned, read live from this page, so it follows the numbers instead of freezing them. Markdown for a README, HTML for a documentation site or a project page.
[](https://agentmods.dev/skills/mukul975/privacy-data-protection-skills/art49-derogations)<a href="https://agentmods.dev/skills/mukul975/privacy-data-protection-skills/art49-derogations"><img src="https://agentmods.dev/badge/skills/mukul975/privacy-data-protection-skills/art49-derogations/github.svg" alt="Measured on agentmods" height="20"></a>Or the 80×15 button, for a site that already has a row of RSS and ATOM ones. Only the verdict fits; the numbers stay here.
<a href="https://agentmods.dev/skills/mukul975/privacy-data-protection-skills/art49-derogations"><img src="https://agentmods.dev/badge/skills/mukul975/privacy-data-protection-skills/art49-derogations.svg" alt="Reviewed on agentmods" width="80" height="20"></a>What it costs to keep this loaded
Counted locally with the o200k_base tokenizer, which is exact for GPT models; Claude uses its own tokenizer and its counts differ. Treat this as one consistent yardstick across the catalogue rather than a bill. Prices are per million input tokens.
| Model | Per session | Once invoked |
|---|---|---|
| Fable 5.1 | $0.00089 | $0.02807 |
| Opus 5 | $0.00044 | $0.01404 |
| Sonnet 5 | $0.00018 | $0.00561 |
| Haiku 4.5 | $0.00009 | $0.00281 |
Grade A, and why
art49-derogations scanned grade A with 0 findings against 26 rules in 11 categories — prompt injection, anti-refusal, data exfiltration, privilege escalation, supply chain, agent snooping, system-prompt leakage, SSRF and excessive agency — measured 12d ago.
A static scan of the body, not an audit. Every finding is printed with the line that produced it so you can judge whether it matters here. A mod is markdown that instructs an agent; that is exactly why what it instructs is worth reading.
Nothing flagged
None of the 26 patterns this scan looks for appear in this file: no shell pipes, no recursive deletes, no credential paths, no hidden text, no instruction-override or anti-refusal phrasing, no agent-config snooping. That is not a guarantee, it is the absence of the things that are checkable.
How it starts
The opening of the file, as written. The whole thing — 177 lines — stays where its author put it; the contents beside it link to each section on GitHub.
Assessing Article 49 Derogations
Overview
Article 49 GDPR provides a limited set of derogations permitting international data transfers in the absence of an adequacy decision (Art. 45) or appropriate safeguards (Art. 46). The EDPB has consistently emphasised in Guidelines 2/2018 on derogations under Article 49 (adopted 25 May 2018, last updated 6 February 2018) that these derogations must be interpreted restrictively and are intended as exceptions rather than the rule. They cannot serve as a basis for systematic, large-scale, or regular transfers.
Derogation Conditions
Art. 49(1)(a) — Explicit Consent
Condition: The data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards.
Requirements:
- Specific: Consent must specifically cover the transfer to the identified third country, not merely the processing activity itself.
- Informed: The data subject must be told:
- The specific third country or countries to which data will be transferred
- The absence of an adequacy decision for that country
- The absence of appropriate safeguards (SCCs, BCRs)
- The specific risks arising from this (e.g., government access without EU-equivalent protections)
- Explicit: Must be an unambiguous affirmative statement; implied consent or pre-ticked boxes are insufficient.
- Freely given: No detriment to the data subject for withholding consent; must be a genuine choice.
- Withdrawable: Data subject can withdraw consent at any time; withdrawal does not affect lawfulness of prior transfers.
Athena Global Logistics example use case: A European customer requests that their consignment tracking data be shared with their own broker in a non-adequate country. The customer is informed of the risks and explicitly consents via a signed transfer consent form.
Limitations (EDPB Guidelines 2/2018):
- Cannot be used for systematic, repetitive, or large-scale transfers
- Not appropriate in employer-employee relationships due to the power imbalance (consent is unlikely to be freely given)
- Not a substitute for establishing systematic transfer mechanisms
What ships with it
4 files beside SKILL.md in the same directory: the scripts, references and assets a skill reads on demand. Not counted in the per-session cost; read them before you install if any of them is executable.
What this file has done since we first saw it
Hashed on every crawl. A supply-chain change to an agent config is a question of when, not whether, so the history is kept rather than the latest state alone.
- 12d ago First seen · 177 lines · 89 tokens per session scan A c8ec30538670
art49-derogations is a skill published in the GitHub repository mukul975/Privacy-Data-Protection-Skills (272 stars, last pushed 5mo ago), licensed Apache-2.0. It adds 89 tokens to every session and 2,807 once invoked, about $0.0004 per session on Opus 5. A static security scan graded it A with 0 findings. No closer match exists in the catalogue, so it is treated as the original; first seen 2026-08-30.
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