On 4 June 2021, the European Commission published its long awaited new Standard Contractual Clauses (SCCs).The SCCs are one of a select few mechanisms available to businesses transferring personal data from the EU to third countries.
The new SCCs replace the old SCCs (which can no longer be used on new deals from 27 September 2021). This means that businesses should review and update their templates and bring their systems and processes into compliance with the new SCCs. Businesses have a further 15 months to identify and repaper existing transfers that use the old SCCs, with the new SCCs. While this is a generous period, businesses should not under estimate the time and effort required for the repapering exercise.
As the EU adopted the new SCCs after the UK left the EU, so the new SCCs will not take effect in the UK. The UK Information Commissioner's Office has announced that it intends to consult on and publish its own standard contractual clauses in 2021.
Our privacy, security and information law practice is able to offer a pragmatic, market-leading and cost effective solution to this re-papering challenge working with our alternative legal services business, Condor, using a combination of technology, nearshore and offshore delivery centres to balance quality with cost considerations.
Contact James Buckingham or Renzo Marchini for further information on SCCs and the options for using Condor in repapering existing documents with new SCCs.
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