10/06/2021

Mischon de Reya

The new EU SCCs may not be appropriate

Since the European Commission published new GDPR Standard Contractual Clauses last week, much of the commentary has focused on immediate reactions. However, one area that appears to have gone unnoticed is potentially significant. According to recital 7 of the Implementing Decision, "the Transfer SCCs are not appropriate to use when the recipient is itself subject to the GDPR."

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