November 28, 2021

Volume XI, Number 332

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Reminder for One-Month Deadline to Implement New SCCs in New Contracts

In early June 2021, the European Commission published a new set of standard contractual clauses (SCCs) effective June 27, 2021 for cross-border data transfers and between controllers and processors.  The new SCCs cover changes in data protection laws, including the invalidation of the EU-US Privacy Shield and the fallout from the Court of Justice of the European Union’s (CJEU) Schrems II opinion (regarding US intelligence laws). The new cross-border data transfer SCCs also use a modular approach to allow for more accurate identification of roles and responsibilities of the contracting parties.  In terms of timing, organizations may use the old SCCs in new contracts until September 27, 2021, and contracts existing before September 27, 2021 must change to the new SCCs by December 27, 2022. For additional information on the SCCs, read our K&L Gates EU Data Protection Alert here.

Copyright 2021 K & L GatesNational Law Review, Volume XI, Number 240
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About this Author

Jake Bernstein Seattle Partner Attorney Technology Data Protection K&L Gates LLP
Partner

Jake Bernstein is a partner at the firm’s Seattle office. He is a member of the Technology Transactions and Sourcing practice group, and primarily services clients under the Data Protection, Privacy, and Security focus area. Jake is also a Certified Information Systems Security Professional licensed by (ISC).2

The Washington State Supreme Court does not recognize certification of specialties in the practice of law and this certification is not a requirement to practice law in the state of Washington.

206-370-7608
Associate

Jane E. Petoskey is an associate at the firm’s Seattle office. She is a member of the Technology Transactions practice group, and primarily services clients under the Data Protection, Privacy, and Security focus area. Jane is also a Certified Information Privacy Professional in the United States (CIPP/US) and Certified Information Privacy Manager (CIPM).

The Washington State Supreme Court does not recognize certification of specialties in the practice of law and this certification is not a requirement to practice law in the state of...

206-370-7853
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