Standard Contractual Clauses
On 4 June 2021, the European Commission published its long awaited new Standard Contractual Clauses (SCCs). The SCCs are one of a select few mechanisms available to businesses transferring personal data from the EU to third countries.
The new SCCs replace the old SCCs (which were no longer to be used on new deals from 27 September 2021). This means that businesses should review and update their templates and bring their systems and processes into compliance with the new SCCs. Businesses have a further 15 months to identify and repaper existing transfers that use the old SCCs, with the new SCCs. While this is a generous period, businesses should not under estimate the time and effort required for the repapering exercise.
For organisations that rely on SCCs to transfer personal data outside the UK and the EU, the requirement to re-paper those contracts within the 12-month grace period will be burdensome both in time and cost. Large organisations are likely to need to address hundreds, if not thousands, of contracts that will need to be identified, reviewed, assessed and then repapered with new SCCs.
Having successfully completed GDPR and other re-papering projects for clients involving the remediation of hundreds or thousands of contracts, Condor is already well-versed in repapering exercises.
Condor combines Fieldfisher’s legal expertise with technology and paralegals for a cost-effective and scalable legal service delivery, managing the entire process end-to-end.