European Economic Area

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)→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
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

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 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

Companies are allowed to transfer personal data outside the European Economic Area (EEA) if they are (1) transferring data to an entity within a country 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”) that imposes many of the

No.

Companies are allowed to transfer personal data outside the European Economic Area (EEA) if they are (1) transferring data to an entity within a country 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”) that imposes many of