The European Commission has issued long-awaited draft Standard Contractual Clauses and they have something for everyone…
- Annexes and pick-and-choose modules (C2C, C2P, P2P, P2C).
- Lots of emphasis on the laws of the country of transfer and pushing back on government requests.
- Reiteration of some Article 26 (joint controller agreement) and Article 28 (data processor agreement) provisions.
- Requirements for transparency to the individuals.
- Individual redress, third party beneficiary and liability as among the entities