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.
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