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Carsten A. Kociok

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Carsten Kociok is a data privacy expert with a wide-ranging practice representing domestic and international clients on complex legal issues. He advises clients across all industries on a wide variety of complex matters, including international data transfers, data privacy compliance, litigation, cybersecurity and data breach response. Carsten is a recognized expert on the EU General Data Protection Regulation (GDPR) and other EU and German data privacy laws and a leading specialist in the field of financial technology laws.

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All contracts that used the traditional Standard Contractual Clauses must be updated and repapered by 27 December 2022. To help companies comply with the deadline, Greenberg Traurig’s Data Privacy & Cybersecurity Group has compiled a 90-page guide explaining how to apply the new Standard Contractual Clauses in over 40 different transfer scenarios – ranging from…

After an extended sunset period, time to replace the “old” SCCs runs out on Dec. 27, 2022. After that date, the old SCCs will no longer legalize data transfers to countries outside the European Economic Area (EEA). To avoid compliance risks associated with illegal transfers of personal data, any old SCCs should be updated to…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
  • The EDPB has taken the position that a data subject “cannot be considered a controller or processor,”[1] and, as a result,

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a European Data Subject: Data Subject→Controller (US)→Processor (US)
  • The EDPB has taken the position that a data subject “cannot be considered a controller or processor,”1 and, as a result,

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a European Data Subject: Data Subject→Controller (US)→Controller (non-EEA)
  • The EDPB has taken the position that a data subject “cannot be considered a controller or processor,”1 and, as a result,

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a European Data Subject: Data Subject→Controller (US)→Controller (US)
  • The EDPB has taken the position that a data subject “cannot be considered a controller or processor,”[1] and, as a result,

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a European Data Subject - Data Subject→Controller (US)
  • The EDPB has taken the position that a data subject “cannot be considered a controller or processor.”1 As a result, the

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Other Transfers from EEA Controller - Controller A (EEA)→Employee of Controller A (non-EEA)
  • Background. Company A is a European legal entity that does not have a legal presence in Country Q.  Company A has

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a US Controller to EEA processors (Renvois) - Controller (US)→Processor (EEA) (on deck) (Basic Renvoi)
  • Cross border transfers in the United States don’t need a SCC. Company A is not required under U.S. law or the GDPR

…

The following is part of Greenberg Traurig’s ongoing series analyzing cross-border data transfers in light of the new Standard Contractual Clauses approved by the European Commission in June 2021.

Visual Description and Implications
Transfers from a US Controller to EEA processors (Renvois) Controller (US)→ Processor (Non-EEA)→Sub-processor (EEA)→Controller (US)
  • Cross border transfers from the United States don’t need a SCC. Company A is not required under U.S. law or the GDPR

…