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Andrea C. Maciejewski

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Andrea C. Maciejewski designs and implements privacy and security programs for clients of all sizes – from Fortune 500s to start ups – and in all sectors, including digital entertainment, marketing, online education, retail, and consumer goods. Andrea helps companies navigate the intricacies of multi-jurisdictional compliance programs as well as compliance with sector-specific data privacy and security laws. Andrea offers clients practical legal counsel, striving to understand the underlying business model and provide strategies that manage costs and risks, while attempting to maintain the businesses operations.

Her practice includes international data privacy laws and regulations, including the General Data Protection Regulation (“GDPR”) and China’s Personal Information Protection Law (“PIPL”), as well as U.S. federal and state data privacy laws, such as the Children’s Online Privacy Protection Act (“COPPA”), the Family Educational Rights and Privacy Act (“FERPA”), and the California Consumer Privacy Act (“CCPA”). Some of the specialized documents Andrea drafts include data processing addendums, intracompany agreements, cross-border transfer mechanisms, privacy policies, privacy impact assessments, and data inventories. She has experience in U.S. and multi-national record retention practices, and frequently counsels on updating those practices for compliance with new privacy laws.

Additionally, Andrea provides expert counsel on data concerns unique to video games, eSports, and mobile gaming.

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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

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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

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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

…

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 (US)  Sub-processor (EEA)  Controller (US)
  • Cross border transfers in the United States don’t need an 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 of 2021.

Visual

Summary
  • Cross border transfers in the United States don’t need a SCC. Company A is not required under U.S. law or the GDPR 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
Overview of situation.  Company A in the EEA retains Company Z-1 in the US to process personal data.  Company Z-1 intends to

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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

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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

…