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Answer:
If the processing is undertaken by an employee of an EU-established company and it is done only exceptionally for example when the employee is on a business trip then we are not in front of a cross border data transfer.
What if it is not exceptionally , but rather that the employee lives outside EU and "works from home" ?
In this case, the employer should ensure that any data on the device cannot be stored or processed locally.
One solution would be using a "remote desktop" solution such as Citrix. In this case, we would not be facing a data transfer.
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Jun 19, 2019