Standard Contract Terms post Schrems II: when do you need additional safeguards for data subjects?
23 July 2020
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This week has seen quite a lot of commentary concerning Standard Contract Terms (SCCs) and the possible need to augment them with additional safeguards when transferring personal data to a Third Country. The problem has arisen because the Schrems II judgement (see references) viewed the SCCs as providing a baseline of Data Protection safeguards. It suggested that the controller and processor should implement further safeguards if required, and if the additional safeguards (if required) could not be implemented, then the
