Will you sign appropriate GDPR Standard Contractual Clauses (SCCs) with the institution?
Explanation
Guidance
See GDPR Chapter 5, Art. 46, for SCC information.
Example Responses
Example Response 1
Yes, our company is fully prepared to sign the appropriate GDPR Standard Contractual Clauses (SCCs) with your institution We have already implemented the updated 2021 EU Commission SCCs with several of our European clients Our legal and compliance teams are familiar with these requirements and can work with your institution to execute the appropriate modules based on our controller-processor relationship We understand the importance of maintaining adequate safeguards for international data transfers following the Schrems II decision and have conducted transfer impact assessments for countries where we process data.
Example Response 2
Yes, we will sign appropriate GDPR Standard Contractual Clauses with your institution While our primary data centers are located within the EEA (specifically in Germany and Ireland), we do utilize support staff in the United States and India who may occasionally access EU personal data for troubleshooting purposes We have already incorporated the latest SCCs into our standard data processing agreements and can provide these for review Additionally, we have implemented supplementary technical measures including encryption in transit and at rest, strict access controls, and comprehensive staff training on data protection to address concerns raised by the Schrems II decision.
Example Response 3
No, we are currently unable to sign the GDPR Standard Contractual Clauses as requested Our legal team is still evaluating the implications of the updated 2021 SCCs on our business operations and data flows We do process data for EU citizens in our US-based data centers, and we previously relied on the Privacy Shield framework We are working to develop a compliance strategy following the Schrems II decision and expect to have a solution within the next 3-4 months In the interim, we can discuss alternative temporary arrangements or limitations on data processing if needed for your institution We understand this is a significant compliance requirement and are actively working toward a solution.
Context
- Tab
- Privacy
- Category
- International Privacy

