The EU has adopted two new sets of Standard Contractual Clauses (SCC). The Cross-Border SCC is the first and it becomes applicable June 27, 2021. From then until September 27, 2021, the old and new SCC can be used. After that, new contracts must use the new SCC, which is consistent with GDPR and the Schrems II ruling, though old agreements will be honored if deemed appropriate. By December 27, 2021, all old SCC’s need to be replaced. To ensure compliance, organizations should review and make appropriate changes to international data transfers from the EU as soon as possible. The second set of SCC changes is specific to the controller-processor data processing agreements.
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