Guest user Created: Jun 20, 2018 Last commented: Jun 20, 2018

Transferring personal data

1. We also need to use cross border agreement when using a third party supplier not established in the EU/EEA and which is not under the adequacy decision. Would it be ok to change the text in the following way processing of personal data is carried out by subsidiaries or third party suppliers of the Company which are based in other Member States;

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Andrei Hanganu Jun 20, 2018

2. What do you mean by “substantially affects” in alternative b) I can’t really see that there is a requirement that our head office located din Norway would need to have a cross border agreement to process data for our employees located on branch offices within EU such as UK, Netherlands, Sweden.

Answer:

1. If you are transferring personal data to a third party located outside the EEA than this is consistent with a cross border data transfer and certain safeguards such as Standard Contractual Clauses (SSC) need to be in place in order for the transfer to be consistent with the EU GD PR requirements.

2. As mentioned above transfers to countries which are within the EEA is not considered a cross border transfers thus, there is no need for the SSCs or other safeguards.

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Jun 20, 2018

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