On 25 May, the European Commission gave us a GDPR birthday present: a Q&A document for the 2021 SCCs. Are they really clarifying key issues, or creating more confusion?
Are the "DPA-SCCs" mandatory to use for your data processing agreements (Article 28(3) terms)? Do you have to sign every document part of your contractual setup? If a controller objects to a suggested new sub-processor, do you have to oblige - meaning you can never appoint new ones, ever? 🤔 So many questions! And we try to cover some of these in today's episode.
Links and resources:
- The Commission's SCCs page
- Direct link to the Q&A PDF
- The LinkedIn post mentioned, where the conversations is on 🔥🔥🔥
- Another LinkedIn post created in September 2021 - the "New SCCs emergency help"