Old EU SCCs currently rescinded

Photo of Davinia Brennan

When the European Payment embraced the brand-new EU Requirement Contractual Conditions (new SCCs )for worldwide information transfers previously this year, we highlighted 3 essential days to be knowledgeable about. As one of those days– 27 September 2021– has actually currently passed, its timely to remind ourselves why

  • those dates are necessary. 27 June 2021 From this date the new EU SCCs might be made use of by firms moving information from EEA to non-EEA countries. 27

    September 2021

    • From this date the old EU SCCs (based on European Commission Implementing decisions (2001/497/EC) and also (2010/87/EU)) were reversed. This indicates that the old EU SCCs can not be used for any type of brand-new agreements participated in from 27 September 2021 onwards, in order to legitimise the transfer of individual information from the EEA to non-EEA countries under the EU GDPR. The brand-new SCCs have to be made use of from this date.

    27 December 2022

    • Existing agreements including the old SCCs stay legitimate up until 27 December 2022 (on the problem that the underlying handling operations continue to be unchanged as well as the transfer is subject to appropriate safeguards).

    This means that business currently have 15 months delegated change all agreements incorporating the old SCCs with the brand-new SCCs. Replacing tradition SCCs will likely be a significant job for numerous organisations, and will entail greater than merely exchanging out the old clauses for the brand-new stipulations. It would therefore be sensible for organisations to begin taking steps currently to examine their information circulations as well as which data transfer contracts need to be evaluated as well as changed.

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