27 September is a key date with regard to the implementation of standard contractual clauses (SCCs). The old set of SCCs can no longer be used in agreements concluded as this key date: the new set of SCCs must now be used. Existing agreements containing the old set of SCCs will remain valid until 27 December 2022, unless the processing operations are altered before that date, or unless parties decide to amend the existing agreement. We therefore underline the importance of a timely transition to the new SCCs. More information on the new SCCs can be found in our recent blogpost.
By Edouard Cruysmans and Erik Valgaeren