Today, the European Commission published finalized versions of new Standard Contractual Clauses (SCCs). The Commission has published two sets of clauses:
- A set of SCCs to be used in controller-to-processor situations in conjunction with Art. 28 GDPR “data processor” terms applicable to such situations.
- A more general set of modular SCCs that can be used to support transfers of data to third countries in controller-to-controller, controller-to-processor, processor-to-processor, or processor-to-controller situations.
The new SCCs will enter into effect 20 days after they are published in the EU’s Official Journal. Alston & Bird is closely reviewing the new SCCs and will provide more detailed analysis in the coming days.