In the PDP Rules, not the term “simple contractual clauses”, but the title “undertakings” is employed, that is regulated less than Article nine(2)(b). The Board blogged several additional sets of new conditions as included into this new endeavors as the minimum criteria within scope out-of transborder transfers off information that is personal. You to place is for transfers throughout the control to your controller, while the other is actually for the newest transmits about control to the latest processor.
The greatest change of these efforts regarding the simple contractual clauses regulated lower than GDPR is the fact that the clauses consisted of because of the these types of set was amendable advice offered to deals. Also, regardless of the amendments built in the fresh sets of efforts, all the endeavors need to be published to the new Panel for the worried transborder transfer to feel approved by the Panel.
With the , the brand new Panel composed an announcement regarding the issues are experienced from the endeavors getting available to the newest transborder transfer off personal information. This statement is designed to prevent prominent deficiencies and you will problems on the apps to have authorization regarding transborder transfer off private information because of submission an undertaking towards the Panel.
At the time of , the fresh Panel established its consent out-of four transborder transfers through to looking at the fresh new registered efforts, as well as the earliest consent statement are dated . Due to the impede inside planning procedure for the latest programs and you will the a lot of time interval between your earliest authorization day and active big date of your own PDP Rules, so it system was not an excellent and you can timely-paced choices.
dos.1.step one.dos.3. Joining business statutes
To the , the brand new Panel blogged a statement into the joining business rules (BCR) and you may stated that BCR may be used inside principles place ahead of the Panel given that option system to the transborder transfer off private information. Lanjutkan membaca “This type of undertakings do not keep the transfers from a chip to a different processor or an operator”