The European Data Protection Board's new guidelines on the interplay between Article 3 and Chapter V of the EU General Data Protection Regulation answer the threshold question that underpins GDPR’s data transfer regime — what is a transfer? The answer comes across as straightforward, but the debate behind it and its implications are anything but simpe. In this article, the IAPP dives into the practical impacts and policy considerations stemming from the new guidance. The IAPP provide further analysis of the EDPB's transfer guidance, spelling out the crucial points of interest in the guidelines privacy professionals need to take into account.
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