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.
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Controller (EEA)→ Controller (US)→ Controller (non-EEA)
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.
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Visual |
Implications |
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Cross-Border Transfer Master Class: Transfers from EEA Controller to non-EEA Controller: Controller (EEA) → Controller (U.S.) → Processor (Non-EEA)
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Cross-Border Transfer Master Class: Transfers from EEA Controller to non-EEA Controller: Controller (EEA) → Controller (U.S.) → Processor (U.S.)
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Cross-border Transfer Master Class: Does a U.S. controller need to use the SCCs when it onward transfers data received from a European to a non-EEA processor?
Companies are allowed to transfer personal data outside the European Economic Area (EEA) if they are (1) transferring data to an entity that is within a country that has been recognized by the European Commission as ensuring an adequate level of protection or (2) they have put in place a European Commission-approved mechanism (a “safeguard”)
Cross Border Transfer Master Class: Onward transfers from a US controller to a processor that is outside of the US and the EEA
Companies are allowed to transfer personal data outside the European Economic Area (EEA) if they are (1) transferring data to an entity that is within a country that has been recognized by the European Commission as ensuring an adequate level of protection or (2) they have put in place a European Commission-approved mechanism (a “safeguard”)
Cross Border Transfer Master Class: Onward transfers from a US controller to a US processor
Companies are allowed to transfer personal data outside the European Economic Area (EEA) if they are (1) transferring data to an entity that is within a country that has been recognized by the European Commission as ensuring an adequate level of protection or (2) they have put in place a European Commission-approved mechanism (a “safeguard”)
The ‘Other SCC’: June 4, 2021 EU Commission Decision on Data Processing Agreement Standard Contractual Clauses
So much has been said about the new Cross-Border standard contractual clauses (SCC), which the EU Commission finally adopted on 4 June 2021 (see GT blog post from 9 June 2021), that it almost went unnoticed that the Commission published two different kinds of SCC that day. The other set of SCC (the DPA-SCC)
Thinking beyond the law: Does the ISO 27701 privacy framework use the same principles that are found within the ISO 29011 framework?
The ISO 29100 privacy framework sets forth the following eleven core principles:
- Consent and choice
- Purpose legitimacy and specification
- Collection limitation
- Data minimization
- Use, retention and disclosure limitation
- Accuracy and quality
- Openness, transparency, and notice
- Individual participation and access
- Accountability
- Information security
- Privacy compliance
The ISO 27701 privacy framework is not explicitly organized using the
Is an outsourced call center a processor or controller under the GDPR?
A controller refers to the entity that determines the “purpose and means” of how personal data will be processed. Determining the “purpose” of processing refers to deciding why information will be processed. Determining the “means” of processing refers to deciding how information will be processed.1 That does not necessarily mean, however, that a controller