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Jurisdiction(s):
European Union

Practical guide to the EU GDPR 2021 Standard Contractual Clauses for international transfers: modules, scope, Schrems II transfer impact assessments, onward transfers, incorporation, governing law and liability

Published by a LexisNexis EU Law expert
Practice notes
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This Practice Note offers detailed guidance on the European Commission’s June 2021 set of the standard contractual clauses (SCCs) for cross-border international transfers of personal data (the 2021 EU SCCs). It delivers a deeper examination of international transfers under the EU’s General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR), than the introductory Practice Note: EU GDPR—transfers of personal data internationally and to international organisations, and proceeds on the basis that readers already understand core concepts within the EU GDPR framework and its international transfer rules. If this area is new to you, you may prefer to consult those Practice Notes first. For basic orientation and context on the EU GDPR more generally, see Practice Note: The EU’s General Data Protection Regulation (EU GDPR).

In brief

Within the EEA, data protection law aims to ensure information about living people (ie falling within the meaning of ‘personal data’) is handled fairly and with accountability. To secure this, the EU GDPR places extensive duties on those who undertake or determine the ‘processing’ of personal data. In essence, ‘processing’ covers doing almost anything with personal data, such as storing, sharing, deleting, using or transferring it. A principal safeguard under the EU GDPR is...

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Lorna Louise Cropper
Lorna Louise Cropper

Lorna advises on data protection compliance and strategy across a range of sectors including technology, gaming, social media, cloud computing, retail and healthcare. She has in depth experience of working on extensive GDPR compliance projects including accountability, an area of particular expertise. As the topic of regulating children's data and children's activity online grows exponentially and with the ICO's Age Appropriate Design Code now in force, Lorna has become a go to expert in children's data.She has an in depth knowledge of working on complicated, large scale data subject access requests (DSAR) including contentious employee DSAR as well as dealing with complaints made by data subjects to the regulator and managing subsequent regulatory investigations.During 2019 – 2020 Lorna undertook a secondment to the Information Commissioner's Office. A keen supporter of Fieldfisher's pro bono work, Lorna is also a regular contributor to...

Anna Rawlinson
Anna Rawlinson

Anna is a Senior Associate in Fieldfisher's Privacy, Outsourcing and Technology team. She advises on a wide range of data protection issues in various commercial context, including comprehensive data protection compliance, data processing and data sharing arrangements, cross-border data transfers, DPIAs, data breaches, data protection issues in corporate transactions, as well as data audits, information rights and e-marketing. She is a member and contributor of the International Association of Privacy Professionals and holds CIPP/E and CIPM certifications. Anna has a broader corporate background, including roles as a corporate associate at a top tier City law firm and an in-house secondee at a major U.S. energy company. Before qualifying as a solicitor in the UK, Anna worked as a legal adviser in Poland and holds PhD in civil law....

Emma Yaltaghian
Emma Yaltaghian

Emma is an Associate in Fieldfisher's Privacy, Outsourcing and Technology team. Her practice focusses on day-to-day compliance issues including data sharing and processing terms, international transfers of personal data including transfer impact assessments and data breach response. Emma works with a wide range of clients on specialist issues, including food and drink manufacturers, medical technologists and large tech companies. Emma recently completed a secondment to an over-the-top messaging provider....

Web page updated on 22/05/2026

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