The SCC transition period expires 27 December 2022.
After 27 December 2022, relying on previous versions of the SCCs will no longer constitute a lawful basis for the transfer of personal data outside the EU/EEA.
If your organisation hasn’t already made the necessary changes, we strongly encourage you to identify any direct transfers out of the EU/EEA still relying on the “old” SCCs and implement corresponding new SCCs, just in time for the Christmas.
Further, we also encourage you to check with your vendors, to ensure that they have made necessary adjustments in relation to potential onward transfers out of the EU/EEA.
On 4 June 2021, the European Commission adopted new Standard Contractual Clauses (also known as SCCs) for transfer of personal data to third countries (countries outside the EU/EEA). The Commission granted a transitional period (“grace period”) during which already concluded SCCs, based on the old SCCs, could remain in use as lawful basis for transfer of personal data to countries outside the EU/EEA. However, this transition period expires 27 December 2022.
If you have any questions or concerns in relation to transfers of personal data to countries outside the EU/EEA, how to apply the new SCCs, etc., our GDPR specialists at Gorrissen Federspiel remain at your disposal.