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ARTICLE · 06 OCTOBER 2021

International Data Transfers – Where Are We Now?

Shepherd and Wedderburn
Shepherd and Wedderburn
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For organisations transferring personal data from the EEA, the new form of model clauses must now be used for any new transfers agreed as of 27 September 2021.

United KingdomPrivacy
Joanna Boag-Thomson
Joanna Boag-Thomson
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Executive Summary

  • For organisations transferring personal data from the EEA, the new form of model clauses must now be used for any new transfers agreed as of 27 September 2021.
  • Existing arrangements using the "old" European model clauses have until December 2022 to be replaced with one of the new versions.
  • The Information Commissioner's Office (ICO) is consulting on the form of model clauses that will be used in the UK for personal data transfers but, until the final form is approved, the old form European clauses (as modified for the UK) should continue to be used.

27 September 2021 was an important milestone for international personal data transfers. The last few months have seen significant developments in this area as the legal framework around regulating such data transfers in Europe and the UK has changed markedly. The key issue for EU/EEA-based organisations is that as of Monday 27 September any new data transfers that need to be regulated

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