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Now in effect.
The replacement Standard Contractual Clauses for use in transfers of data outside the EEA are effective from 27 June 2021.
Significant new obligations.
The new SCCs have been constructed in a modular manner and allow for greater flexibility in importer/exporter relationships, however they impose significant new obligations on data importers in particular and will be onerous for organisations to comply with.
Organisations have until:
- 27 September 2021 for all new transfer arrangements
- 27 December 2022 for all transfer arrangement entered into up to the September deadline.
For many organisations, this will mean a large repapering exercise.
The implementation project for the New SCCs is not limited to the repapering exercise; organisations will need to ensure that their data mapping is comprehensive and up to date, put in place an operational framework for carrying out transfer impact assessments and complete those assessments for all existing transfer arrangements to third countries.