Data transfer

To what extent should we use Annex 2 of the Cross-Border Data Processing Procedure for:
- the application of visas for countries such as America, India, China, etc.? Consulates will not be prepared to sign Annex 2.
- the reservation of hotels, renting cars in e.g. the above-mentioned countries?

Answer:

1. If you apply for visas you don`t need to have a data transfer mechanism in place as the transfer of data is regulated via International Agreements between countries.
2. If the data subject does that directly there is no need for such data transfer agreement. However, if a company in the EEA would be passing personal data to a car rental company outside the EEA a data transfer agreement would be needed between the two entities.

To learn more about data transfers check out our webinar “How to make personal data transfers to ot her countries compliant with GDPR” (https://advisera.com/webinars/how-to-make-personal-data-transfers-compliant-with-gdpr-free-webinar-on-demand/)