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Deadline for Implementation of Standard Contractual Clauses (SCC) is Approaching

Effective December 27, 2022, organizations must implement Standard Contractual Clauses in order to transfer personal data outside of the European Union.

On June 27, 2021, the European Commission adopted new Standard Contractual Clauses (SCCs) for organizations to implement for transfers of personal data to third countries without adequate data protection. This was a response to the July 2020 Schrems II decision, where the European Union ("EU") invalidated the EU-US Privacy Shield. This decision ultimately held that the United States is a "third country" that lacks an adequate data standard.

Based on the European Commission's guidance, by December 22, 2022, Certiphi Screening must have SCCs in place with all existing clients.

Certiphi Screening recommends that clients begin to reach out to their respective Account Managers for a copy of the SCCs. Certiphi Screening will also provide to our main contacts at our affected clients, a copy of the SCC's for review for execution. Prompt acknowledgement from clients is most appreciated, as we require SCC compliance in advance of the December 22, 2022 deadline.

Clients should be aware that at this time, the SCCs only apply to data transfers from the European Union, which does not include the United Kingdom (UK). The United Kingdom Information Commissioner is currently considering a "UK addendum" to data transfer agreements such as the SCCs. Certiphi Screening will notify clients as more information becomes available regarding UK data transfers.

Posted: September 23, 2021


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This document and/or presentation is provided as a service to our customers. Its contents are designed solely for informational purposes, and should not be inferred or understood as legal advice or binding case law, nor shared with any third parties. Persons in need of legal assistance should seek the advice of competent legal counsel. Although care has been taken in preparation of these materials, we cannot guarantee the accuracy, currency or completeness of the information contained within it. Anyone using this information does so at his or her own risk.

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