On June 4, 2021, the European Commission authorized the new Standard Contractual Clauses (SCCs) for transfers of personal data from Europe to the United States and other countries that EU deems to not offer “adequate” levels of data protection. The expansion of SCCs, which now cover transfers from data processors and non-EU exporters, as well as the inclusion of Transfer Impact Assessment (TIA) guidance, should bring some more certainty to companies and allow SCCs to continue to fulfill the role of mainstay of cross-border data transfers. In this initial look at the updated SCCs we will address:
- SCC transfer options – C2C, C2P, P2P and P2C – through practical use cases
- Key changes in SCC requirements
- Impact of SCC revisions on scope of “transfer” under GDPR
- New guidance on TIAs / Regulation of requests for personal data from public authorities
- Transition period. Practical tips on transitioning to the new SCCs.
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