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Andrea C. Maciejewski advises clients on compliance with local and international data privacy regulations including the GDPR, CCPA, COPPA, CAN-SPAM , TCPA, and state biometric laws. She guides clients on data breach response and privacy policies.

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 of 2021.

Visual Summary
Overview of situation.  Company A in the EEA retains Company Z-1 in the US to process personal data.  Company Z-1 intends 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 of 2021.

Visual Summary
  • 1st Transfer: SCC Module 2. Initial cross-border transfer from EEA to Country Q utilizes the SCC Module 2 designed for transfers from

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 Summary
Transfers from EEA Controller to non-EEA Processor: Controller A (EEA)→Processor Z (US) →Processor X (US) →Controller A (EEA)
  • 1st Transfer: SCC Module 2. Initial cross-border transfer from EEA to United States utilizes the SCC Module 2 designed for transfers from

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 Summary
Transfers from EEA Controller to non-EEA Processor: Controller A (EEA)→ Processor Z (non-EEA) → Controller A (EEA)
  • 1st Transfer: SCC Module 2. Initial cross-border transfer from EEA to a non-EEA country utilizes the SCC Module 2 designed for transfers

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 Summary
Transfers from EEA Controller to non-EEA Processor: Controller A (EEA) → Processor Z (US) → Controller A (EEA)
  • 1st Transfer: SCC Module 2.  Initial cross-border transfer from EEA to United States utilizes SCC Module 2 designed for transfers from a

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 Implications
  • Background. Company Z-1 and Company Z-2 are corporate affiliates who are under common ownership or control, but are separate legal entities. Data is

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 Implications
Transfers from EEA Controller to EEA Processor: Controller (EEA)→ Processor (EEA) → Affiliated Processor (US)
  • Background. Company Z-1 and Company Z-2 are corporate affiliates under common ownership or control, but are separate legal entities. Data is being directly

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 Implications
Controller (EEA) Processor (EEA) → Employee of Processor (non-EEA)
  • Background. Company Z is a European legal entity that does not have a legal presence in Country Q. Company Z has an employee

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 of 2021.

Visual Implications
  • 1st SCC Module 1. Initial cross-border transfer from Company A to Company B utilizes the SCC Module 1 designed for transfers from

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 of 2021.

Visual

Implications

  • Initial cross-border transfer from the EEA to the US utilizes the SCC Module 1 designed for transfers from a controller to another non-EEA