EU Commission provides guidance on how to use SCCs
Duncan Blaikie, Cindy Knott and Natasha Pappas of Slaughter and May explain the FAQs that are based on feedback received in the first few months since the adoption of the new SCCs.
International transfers under the EU and UK GDPRs continue to be challenging for organisations. Leaving aside the ins and outs of transfer risk (or impact) assessments, often the simple mechanics of how to use the new documentation have created confusion and uncertainty. Helpfully, the EU Commission has recognised this, and, on 25 May 2022, it published guidance in the form of questions and answers(1) (the Q&As). The Q&As cover both the use of Standard Contractual Clauses in the context of international transfers (the SCCs), which this article focuses on, and the use of standard contractual clauses in the context of controller-processor relationships.
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