Member Article

On 27th June 2021, the European Commission unveiled the new set of EU Standard Contractual Causes (‘SCCs’) that are to be used in instances when personal data are to be transferred from the EU/EEA to a third country.

These new SCCs replaced an older version and are now required in those instances where the old SCCs were being relied on, as opposed to other derogations that may be applicable, for any contract involving transfers of personal data to third countries, signed after the 27th September 2021. Meanwhile a transitory ‘grace’ period was granted to any contracts which already incorporated the old version of the SCCs. However that grace period is set to expire on the 27th December 2022.

Any entities, whether a data controller or data processor, still making use of the old SCCs must ensure to update them and have the new version signed and in place by the deadline of 27th December 2022. Not having the new SCCs in place by then, will constitute an infringement of Chapter V (Articles 44-49) of the GDPR, which is subject to the maximum fines under the said GDPR.

More information on the SCCs can be found in our original article on the matter here:

Transfers of Personal Data to Third Countries: A Brief look at the New SCCs

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Disclaimer: This document does not purport to give legal, financial or tax advice. Should you require further information or legal assistance, please do not hesitate to contact [email protected] 

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