Practical Next Steps On SCCs Project

UK and EU data privacy law (and indeed many other privacy laws outside EMEA aswell) restrict transfers of personal data outside the UK or EU unless an exemption applies which is narrowly defined. One of these exemptions is reliance on standard data protection clauses adopted by the EU Commission, commonly known as the standard contractual clauses ("SCCs"). On 4 June 2021 the EU published an updated version of the SCCs (the "New EU SCCs") which are modular in their approach and require much more work to put in place than the SCCs aswell as greater privacy compliance by both parties. Currently, the SCCs can continue to be relied upon until 27 December 2022 ("the Deadline"); provided that (i) the contract was concluded before 27 September 2021 and (ii) the processing activities and categories of data under the contract remains unchanged