Starting the 27th of September 2021, new standard contractual clauses for the transfer of personal data to third countries must be entered into. Any transfers of personal data from the EU to recipients located in third countries relying on Standard Contractual Clauses (SCCs) will need to be based on the new set of SCCs as adopted in June of 2021 by the European Commission (Décision UE 2021/914).

Make sure to update your DPA’s with the new SCC’s and understand your new obligations.

Together with additional technical safeguards, you should start implementing the new SCCs, e.g., if  you are transferring EU personal data to a third country (such as the US) or If you are using a service provider (sub-processor) that is based in the US (e.g., through hosting services).

For existing contracts, conversion is required by 27 December 2022. Contracts entered into before the 27th of September 2021 that rely on former standard contractual clauses will remain valid for a period of 15 months ending on 27 December 2022.

We would be pleased to assist you in connection with processing arrangements and in the implementation of these much stricter clauses.

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