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Can a controller subject to the UK GDPR and EU GDPR rely on the Directive SCCs to comply with the data transfer requirements under both data protection regimes?
Practical Law Resource ID a-133-4021 (Approx. 5 pages)
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Can a controller subject to the UK GDPR and EU GDPR rely on the Directive SCCs to comply with the data transfer requirements under both data protection regimes?
Anonymous (Private practice)
Q:
We have a UK-based controller. The controller wants to send personal data (PD) outside of the EEA and thus uses the UK standard contractual clauses (SCCs). If the same UK-based controller wanted to send EU citizen data outside the EEA, do they need to use the EU SCCs or can they rely on the UK SCCs (meaning the set which has been marked up with UK terms?
That is, does the controller require two sets of SCCs, one for the UK to outside the EEA and another for the UK (EU citizen data) going out of the EEA?
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