Navigating Post-Schrems II International Data Transfer Waters: SCCs and Supplementary Measures

Developments such as the recent decisions from Austrian and French data protection authorities that use of Google Analytics violates the GDPR and the adoption of new E.U. standard contractual clauses (SCCs) highlight the need for companies to address shifting requirements for legally transferring data out of the E.U. In this second installment of a two-part article series, we share insights from Hogan Lovells, Greenberg Traurig and Steptoe & Johnson partners about trends and suggested approaches to SCCs and supplementary measures, as well as the impact of the recent Google Analytics decisions. Part one addressed some of the biggest challenges for companies, how and when companies are using binding corporate rules, and provided advice on conducting the transfer impact assessment. See our two-part series on personal data transfers after year zero: “Are the New SCCs a Paradigm Shift?” (Jun. 30, 2021); “A More Appealing Set of EDPB Recommendations?” (Jul. 14, 2021).

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