The EU Commission's new standard contractual clauses may impose significant burdens on companies wishing to use them, particularly smaller businesses. In this article, the IAPP looks at the challenges small companies may face with the new SCCs. "Smaller companies, however, may lack the necessary legal expertise and staffing to carry out the risk analysis, documentation and monitoring articulated in recommendations," the IAPP writes. "The burden on these companies is so significant that obligations imposed by the new SCCs and supplemental measures could question whether they can transfer data at all."
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