Recommendations
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Safeguarding data flows: Joint trade associations recommedations on EDPB supplementary measures
BRUSSELS, December 21 – A broad coalition of industry federations, including the European Banking Federation, have published a joint statement to raise their concerns on the European Data Protection Board’s (EDPB)’s Recommendations on supplementary measures following the Court of Justice of the European Union (CJEU) ruling in the so-called Schrems II case.
While the Recommendations aim to offer clarity on the use of tools for the transfer of personal data outside the EU, notably on standard contractual clauses (SCCs), the result is an overly prescriptive approach which conflicts with the risk based approach of the GDPR, thereby risking to make data transfers unnecessarily difficult for businesses and risks continuing uncertainty that has followed the Court’s judgement.
The final Recommendations should take a more risk-based approach to data transfers that takes the full context of data transfers into account and allow businesses to continue relying on contractual and organisational measures.
Contact:
Liga Semane, Policy Adviser, Data & Innovation l.semane@ebf.eu
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