The Future of Privacy Forum (FPF) has published a new report comparing three different model contractual frameworks covering 62 countries across three continents.
- EU’s Standard Contractual Clauses (SCCs)
- ASEAN Model Contractual Clauses (MCCs)
- Iberoamerican Network’s Model Transfer Agreement (MTA)
The report aims to identify any significant overlaps and differences in the following areas:
- Underlying Legal Basis for Use of Contractual Framework
- Core Party Obligations
- Data Subject and Third-Party Rights
- Response to Government Requests
- Relevance to Cross-Border Enforcement
- Permissibility of Modifications
The report concludes: "Overall, a path towards a global framework or at a minimum interoperable frameworks that allow international transfers of personal data on the basis of standard contracts is visible following the detailed comparison made in this study.
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