As of August 13th, 2022, Legislative Decree No. 104 dated June 27th, 2022 (the so-called “Transparency Decree”), implementing Directive (EU) 2019/1152, came into force, establishing specific privacy obligations for employers, who make use of automated decision-making or monitoring systems.
Following our previous analysis of the consequences of the opinion of the advocate general Hendrik Saugmandsgaard Øe (a.g.) in the Schrems II case, from the data exporter perspective (available here), we now focus on the implications of the same with respect to the position of the data importer. Indeed, in the following paragraphs, we will turn our attention to the content of the Controller to Processor Standard Contractual Clauses (SCC) and, in particular, to some…
In this blog post we further analyse the impacts of the opinion of the advocate general Hendrik Saugmandsgaard Øe (a.g.) in the Schrems II case. We will focus, more specifically, on what it means for data exporters and what consequences there may be for them, if the decision of Court of Justice of the European Union (CJEU) on the case is consistent with the a.g’s opinion. Data importers will be the focus of another post,…