Schrems II judgment

Padlock and EU flagWe are one (penultimate) step closer to the final adoption of new Standard Contractual Clauses (“SCCs”) by the European Commission.

The final version of a long overdue update to the 2004 (in case of controller-to-controller)/2010 (in case of controller-to-processor) model clauses which companies use to safeguard personal data transfers to controllers/processors outside the EEA under Article 46.2(c) of the GDPR, has cleared one of its final hurdles.

Today, the Article 93 Committee, consisting of the representatives of EU governments, unanimously approved new draft SCCs proposed by the Commission. The Committee is named after Article 93 of the GDPR, referencing the examination procedure, which the draft SCCs of the European Commission (including the one on the new SCCs) had to go through on its way to final adoption.
Continue Reading New Standard Contractual Clauses for Transfer of Personal Data outside the EEA – Getting Warmer by the Day