Spotlight on SCCs for International Data Transfers
On 4 June 2021, the European Commission adopted new SCCs to enable lawful transfers of personal data to countries outside the EEA. The new SCCs take into account the CJEU's Schrems II decision by including specific provisions on government access requests in the recipient country (see our blog post for details).
Unlike the existing sets of SCCs, which included two different versions (controller to controller and controller to processor), the new SCCs adopt a modular concept that cater to various transfer scenarios:
Controller to controller transfers;
Controller to processor transfers;
Processor to processor transfers; and
Processor to controller transfers.
The Hogan Lovells SCC Tool helps to select the appropriate module(s) and adjust the SCCs as applicable to your data transfer(s).