Schrems privacy impact assessments

The final version of the new standard contractual clauses (“SCCs”) were published by the European Commission on June 4, 2021. Many organizations that transfer or receive personal data originating in the European Economic Area (“EEA”) outside the EEA will be required to implement these SCCs with their customers, suppliers and affiliates by December 2022 to comply with the EU General Data Protection Regulation (“GDPR”). This is perhaps the most significant GDPR development since the passage of the GDPR. We had foreshadowed this impending development last week.