The term “Transfer Impact Assessment” or “TIA” is relatively new to the world of data privacy. Indeed, according to one widely used legal database the term was not referenced within any academic journals or secondary sources until 2021.[1] The term has come to refer to a written analysis, conducted by a controller or 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 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 (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

Modern privacy laws contain different definitions for the term “consent,” and different standards for when consent will, and will not, be effective.

In Europe, the right of an individual to withdraw consent for the processing of their personal data has become near axiomatic and is often referred to by Member State supervisory authorities. The right

The impetus to conduct a Data Transfer Impact Assessment (TIA) comes from three legal authorities: (1) the European Court of Justice’s recommendation in Schrems II that the parties to a transfer verify on a case-by-case basis whether the “law of the third country of destination ensures adequate protection . . . of personal data transferred