Easier implementation of Binding Corporate Rules after eBay's and other recent successes – Tom De Cordier
summary
Argues that Binding Corporate Rules work by shifting cross‑border transfers to an accountability‑based model, detailing five enforceable elements: a comprehensive data protection policy, operational mechanisms that include liability and complaint handling. Recommends regular internal and independent audits, explicit transparency and individual access rights. Notes the third‑party beneficiary clause and enforcement mechanism require significant negotiation but are now acceptable to DPAs after eBay and similar approvals, so BCRs are practical, not just theoretical.
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