![]() ![]() A new data transfer tool for this scenario will be needed. Lastly, as readers may know, the recently adopted SCCs may not be suitable for use when an exporter is sending data to an entity in a third country which is already subject to GDPR (see our blog under the heading "What about transfers to importers that are already subject to the GDPR?"). The importer must be in a third country outside of the EEA (or be an international organisation) regardless of whether it is itself subject to the GDPR. So, remote access to EU data by a travelling employee from outside of the EEA will not qualify as a transfer.ģ. The transfer must be from a controller / processor to another.
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