Key Issues Relating to Standard Contractual Clauses for International Transfers and the Way Forward for New Standard Contractual Clauses under the GDPR

The European Commission is currently working on updated standard data protection clauses for international transfers (SCC) to serve as “appropriate safeguards” that are necessary to legitimize the transfer of personal data to a third country in the absence of an adequacy decision.

The Commission is currently receiving input from organizations. CIPL welcomes the opportunity to submit this paper.

This Paper is intended to highlight the main challenges organizations face when relying on the existing SCC and to propose practical ways to overcome these challenges when updating the clauses to the GDPR and to the reality of current business relationships and data uses.

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