• DIGITALEUROPE replies to Commission International Data Transfer Communication

    12 May 2017On 22 May, DIGITALEUROPE sent a letter to the European Commission regarding its recent International Data Transfers Communication. The Communication, published in January 2017, set out the Commission’s future agenda on ‘exchanging and protecting personal data in a globalised world’ and covered issues related to adequacy decisions, potential new standard contractual clauses (“SCCs”) and possible future Binding Corporate Rules (“BCRs”) developments.

    In its letter, DIGITALEUROPE expressed its belief that it is the right time for the Commission to begin utilising all parts of the international data transfer ‘toolkit’, particularly adequacy decisions. We believe that the creation of a ‘international data flows’ unit within DG JUSTICE will help to facilitate this work.
    Along with adequacy decisions, we noted our encouragement by the potential development of processor-to-processor SCCs to complement the existing set of SCCs and called on the Commission to embark on such an exercise in cooperation with the Article 29 Working party. We also supported the exploration of potential convergence between EU BCRs and Asia Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPRs”), but hope that this would go beyond a general ‘mapping’ of similarities between the two mechanisms and instead believe the Commission should strive for the ambitious goal of mutual recognition.
    For more information you can find DIGITALEUROPE’s letter here.


    For more information please contact: 

    Damir Filipovic Photo Damir Filipovic
    Alexander Whalen Photo

    Alexander Whalen
    Senior Policy Manager

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