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Handling the New SCC in Practice

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New EU standard contractual clauses replace old ones for new transfers as of 27 September 2021, while pre-26 September agreements remain usable until the end of next year. The clauses are four-module modular SCCs (controller→controller, controller→processor, processor→processor, processor→controller), embed a mandatory transfer impact assessment and specific obligations for responding to government access requests, require detailed Annexes naming technical and subprocessor measures, and force documented data-mapping, project planning and contractual warranties.

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  1. 0:00Start
  2. 0:31Handling Standard Contractual Clauses
  3. 7:13Standard Contractual Clauses
  4. 19:39Specific Obligations of the Data Importer
  5. 21:42Risk-Based Approach
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