The UK’s Information Commissioner Office’s has issued a revised statement on the Schrems II.
“Further work is underway by the European Commission and EDPB to provide more comprehensive guidance on extra measures you may need to take. In the meantime you should take stock of the international transfers you make and react promptly as guidance and advice becomes available”.
“The EDPB has recommended that you must conduct a risk assessment as to whether SCCs provide enough protection within the local legal framework, whether the transfer is to the US or elsewhere. The receiver of the data may be able to assist you with this.”
” We are … taking the time to consider carefully what this means in practice. We will continue to apply a risk-based and proportionate approach in accordance with our Regulatory Action Policy.”
” The ICO understands the many challenges UK businesses are facing at the present time and we will continue to provide practical and pragmatic advice and support.”