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.
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.
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.
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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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)
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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.
Controller A (EEA) → Controller B (EEA) → Processor Z (Non-EEA)
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Controller A (Non-EEA) → Processor Z (Non-EEA) → Sub-processor Y (EEA) → Controller A (Non-EEA) (same country)
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It depends on the purpose for which a transfer impact assessment (TIA) is created. It is unlikely that the attorney-client privilege would apply to a TIA that is created, and used, to satisfy the requirements of the Standard Contractual Clauses (SCCs).
The attorney-client privilege in the United States refers to a judicially recognized ability for
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