SCCs Are Here But Far From Standard

Serious Privacy

On this week's episode of #SeriousPrivacy, Paul Breitbarth and K Royal discuss the new Standard Contractual Clauses (SCCs) for international transfers that were adopted by the European Commission on 4 June 2021. These model contracts, that come in four modules, finally replace the old SCCs, some of which date back to the early 2000s. The modernised versions are fully GDPR compliant, embrace the accountability principle and include many requirements to address the limitations set by the Schrems II decision.

Listen to the conversation to get a better understanding of what the new SCCs entail and how they can (and cannot) be used by organisations. You will hear more about why some non-European companies will not have to use SCCs going forward, but also on the assessments that you will need to undertake.
Since recording the episode, the timelines for the Transfer SCCs have become clear too:
27 June 2021 - the new SCCs become applicable
27 Sept 2021 - the old SCCs become invalid for new contracts
27 Dec 2022 - all SCC-based contracts will need to be updated

Resources

• TrustArc blog introducing the new SCCs
• TrustArc microsite with all international transfer related information

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