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Yes, even access from a third country is a data transfer.You need to verify in which country is located your employee, if the country can benefit from an adequacy decision or if you need to annex Standard Contractual Clauses at the agreements with your Clients. On the website of the EU Commission, you can check the country which benefits from adequacy decision under Article 45 GDPR https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en Here you can find the model of the New Standard Contractual Clauses: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj
If you need to know more about how to transfer data in third countries under the EU GPDR here you can find more information:
- 3 steps for data transfers according to GDPR: https://advisera.com/articles/3-steps-for-data-transfers-according-to-gdpr/
- Free webinar – How to make personal data transfers to other countries compliant with GDPR: https://advisera.com/webinars/how-to-make-personal-data-transfers-compliant-with-gdpr-free-webinar-on-demand/
You can also consider enrolling in this free online training EU GDPR Foundations Course: https://advisera.com/training/eu-gdpr-foundations-course/
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Jun 28, 2021