At long last, the European Commission, on June 4, 2021, adopted
new Standard Contractual Clauses ("new SCCs") to permit
lawful transfers of personal data from the European Union (EU) to
third countries such as the United States.1 This
development is critical for U.S. multinational employers that rely
heavily on centralized, web-based platforms for key aspects of
global human resources administration, such as recordkeeping,
performance evaluation, expense reimbursement, and diversity and
inclusion initiatives.
Every U.S. multinational employer that currently relies on the
existing Standard Contractual Clauses ("existing SCCs")
will be required to update numerous agreements. These include
the existing SCCs used to transfer HR data from EU subsidiaries to
members of the corporate group located in the United States and
other third countries, as well as the existing SCCs used to
legitimize transfers of EU personal data to the many service
providers located outside the
