With the start of 2022, clients have to ensure that they are now using the new EU SCCs introduced in June 2021 and that any legacy (ie pre-September 2021) SCCs are transferred to the new regime by 27th December 2022. In addition, the UK Government’s ICO recently announced its own set of SCCs which is timetabled to appear on the statute book by the end of March 2022.
Transfers of personal data outside the EU and UK are governed by applicable data protection law unless the European Commission has granted “adequacy” or the transfer is subject to appropriate safeguards (one such safeguard being SCCs) or the transfer is occasional and nonrepetitive. With the introduction of new SCCs by the EU last year, companies transferring data from the UK to the EU and third countries are being impacted with businesses having to re-paper their data transfer arrangements by the end of 2022 which may be costly in terms of resource and money (and this is without even considering the introduction of new SCCs by the UK Government expected during 2022).
We have developed an end-to-end solution to the SCC repapering requirement by providing the technology and resources to projects involving hundreds or thousands of contracts – by utilising a combination of project management and technology together with a scalable team of lawyers and paralegals structured to meet the client’s needs, Condor can provide a solution on time and with the comfort of fixed pricing.
How We Can Help
Condor is an alternative legal solutions (ALS) provider and a division of Fieldfisher LLP a European law firm with a market-leading privacy, security and information law practice.
Condor ALS provides cost efficient and fixed price alternatives to engagements that previously would have been charged on a time and materials basis, by utilising the right staffing combinations and innovative technologies to deliver and manage work. Condor ALS combines the legal, regulatory and data management expertise of Fieldfisher lawyers with the negotiation, project management and technology
capabilities of market-leading third service providers or our very own near shore teams to offer clients a comprehensive, quality-assured suite of solutions through a single contract.
- Access to Fieldfisher’s leading Privacy, Security and Information Law practice.
- Condor offers end-to-end project management for all large scale repapering exercises.
- Bespoke technology to quickly and automatically analyse and categorise contracts, generate amendment agreements and track negotiation progress.
The Transition Period
With 9 months left of the original transition period organisations should not underestimate the time and effort required to make these changes. The migration to new SCCs will involve:
Amending templates to incorporate the new SCCs.
Completing transfer impact assessment on all data transfers using SCCs.
Identifying data transfers that use the legacy SCCs and those that will need to transition to new.
Prepare new SCCs for legacy data transfers and issue to counterparties.
Negotiate and agree new SCCs with counterparties.
The Value We Add
Condor’s scalable, flexible and cost-effective model enables us to deliver an efficient and cost effective outcome for our clients whenever they need it. We can scale up to meet larger requests so a client can deal with potentially disruptive requests without having to constantly redirect already scarce internal legal resources.
If you would like to learn more about Condor ALS and how we can help you, please get in touch with us now at enquiries@condor-als.com
