Remediating SCCs deadlines: are you ready?

REMINDER - 27 December 2022 is the deadline for updating your old EU SCCs, as after that date they will no longer be valid as a safeguard for transfers of personal data under EU GDPR. If your live contracts contain the old SCCs, do get in touch about our remediation services – including our automated software tools – for assistance in remediating your transfer documentation, whether for the new EU SCCs or the post-Brexit UK GDPR transfers safeguards. Our timeline pullout (here) has the key international transfers deadlines for your calendar.

Background

Following the June 2021 introduction of new Standard Contractual Clauses ("SCCs") by the European Commission to safeguard international transfers of personal data, the deadline for remediating contracts that still rely on the old EU SCCs is 27 December 2022. After this date, all contracts using old SCCs in relation to EU data transfers will be in breach of international transfer requirements under the EU General Data Protection Regulation ("EU GDPR"). This means that any agreements involving transfers of personal data from the EU will need to be updated by 27 December 2022.