Global Data Transfer Agreement

The legal basis for transfers must be explicitly stated. This should include the reference to ongoing direct and indirect transfers (if any) and the legal basis for onward transfers. It is important that the Court of Justice has not annulled the European Commission`s decision authorising certain standard contractual clauses for transfers to data processors (SCC C2P). However, the explanatory memorandum to the Court`s judgment on the Privacy Shield suggests that companies should assess their use of SCC C2Ps, in particular whether the clauses are sufficient to protect the transfer of personal data in cases where third-country law allows its authorities to access this information. If you make a limited transfer from one controller to another controller, you can choose which clauses to use based on which ones best fit your business agreements.