On 4 June 2021, the European Commission issued updated Standard Contractual Clauses ("SCCs") for transfers of personal data to third countries.
The 18-month transition period to update legacy SCCs ends on 27 December 2022. As the EU data protection authorities increasingly focus on the enforcement of the GDPR's international data transfer rules, replacing any old SCCs is important; regulators and pressure groups alike will focus on this area in 2023, and businesses that have not conducting a repapering exercise, even attempted to assess the risks of the transfer, will be easy targets for enforcement and claims.
However, replacing all legacy SCCs can be a resource-intensive and time-consuming exercise.
Practically, the repapering involves:
To assist our clients with their SCC repapering obligations, Linklaters has developed an artificial intelligence tool which supports completion of this process with maximum efficiency.
The tool extracts information from existing SCCs and enables the semi-automated generation of new SCCs using our in-house document automation tool, allowing the whole process to be run in a streamlined, effective and cost-efficient manner. Our lawyers carry out necessary checks at key points during the process to ensure quality of work product.
Your regular privacy contact would be pleased to discuss how our tool can assist with your specific repapering process, and answer any questions you may have.