Florian Tannen – Connect On Tech

In Data Privacy & Security

Consideration for EU Service Providers Supporting EU and Non-EU Customers

The new standard contractual clauses for data transfers to third countries (“Ex-EU SCCs”) and standard contractual clauses for controllers and processors in the EU/EEA (“Intra-EU SCCs”) issued by the European Commission provide for, both, chances and challenges for EU service providers supporting EU and non-EU customers, some of which are outlined below. 1. When do the Ex-EU SCCs apply? EU service providers supporting non-EU customers might want to enter into the new Ex-EU SCCs with…

In EU GDPR

Intra-EU/EEA Standard Contractual Clauses: What you need to know

The European Commission (“EC”) recently issued a set of standard contractual clauses for controllers and processors in the EU/EEA (“Intra-EU SCCs”). The Intra-EU SCCs accompany a wider set of clauses issued for extra-EU/EEA personal data transfers (“Extra-EU SCCs”), covering transfers between different types of data processing actors (processors, controllers, sub-processors etc.). Both of them were published in the Official Journal of the European Union on June 7, 2021. The clauses for intra-EU data processing arrangements…

In Data Privacy & Security

The New European Commission Standard Contractual Clauses: What you need to know

The European Commission (“EC”) recently issued its revised standard contractual clauses for data transfers to third countries (“Ex-EU SCCs”) and a companion set of standard clauses for controllers and processors in the EU/EEA (“Intra-EU SCCs”). Both are now published in the Official Journal. The following is an introduction to the core elements of the Ex-EU SCCs and a brief overview of the Intra-EU SCCs. Legal Context The Ex-EU SCCs are a mechanism that companies can…

In Data Privacy & Security

What ‘Schrems II’ means for companies that rely on derogations

July 27, 2020 by Brandon Moseberry and Florian Tannen 2 Mins Read

Starting with a good note: The “Schrems II” judgment does not lead to significant negative implications for companies that rely on the derogations the EU General Data Protection Regulation provides for international data transfers through Article 49. The Court of Justice of the European Union’s judgment stipulates that companies will need to evaluate whether their use of the standard contractual clauses provides sufficient protection in light of any access by the public authorities of the third country…

In Data Privacy & Security

Schrems II: European Court of Justice Upholds the SCCs and Invalidates the EU-US Privacy Shield Framework

July 16, 2020 by Elisabeth Dehareng, Joanna De Fonseka, Dr Lukas Feiler, Francesca Gaudino, Brian Hengesbaugh, Julia Kaufmann, Wouter Seinen and Florian Tannen 2 Mins Read

The European Court of Justice (“ECJ”) issued a landmark ruling earlier today that invalidates the EU – US Privacy Shield Framework (“Privacy Shield”) in Case C-311/18 (“Schrems II”).