On July 10, 2023, the European Commission adopted its long-awaited adequacy decision on the EU-U.S. Data Privacy Framework (the “Framework”) thereby concluding that the United States ensures an adequate level of protection for personal data that are transferred from the European Union to companies in the U.S. that participate in the Framework.

The

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.

  • Background. Company A is an EEA controller that utilizes Company Z, a processor based in Country Q. Company Z does not have a legal presence

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.

  • Background. Company A is an EEA controller that utilizes Company Z, a processor based in Country Q. Company Z does not have a legal presence

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.

  • Background. Company A is an EEA controller that utilizes Company Z, a processor based in Country Q. Company Z does not have a legal presence

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
Background. Company A retains Company Z in Country Q to process personal data (e.g., collect personal data from data subjects). Company

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
  • Background. Company A transmits personal data to its processor Company Z, and then instructs its processor to onward transfer the personal

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.

Controller A-1 (EEA) → Controller A-2 (Non-EEA)

Visual Description and Implications
  • Background. Company A-1 and Company A-2 are corporate affiliates that are under common ownership

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.

Controller A (EEA)  → Controller B (EEA) → Controller C (Non-EEA)

Visual Description and Implications
  • Background. Company A in the EEA transfers personal data 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.

Controller A (EEA) → Controller B (EEA) → Processor Z (Non-EEA)

Visual Description and Implications
  • Background. Company A in the EEA transfers personal data to