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Are we required to meet the restricted transfer requirements under the UK GDPR when sending personal data to an individual contractor based in India who may be operating as a sole trader or via a limited company?
Practical Law Resource ID a-133-4121 (Approx. 3 pages)
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Are we required to meet the restricted transfer requirements under the UK GDPR when sending personal data to an individual contractor based in India who may be operating as a sole trader or via a limited company?
Anonymous (Private practice)
Q:
A UK based entity has contractors working for them (employed as either an independent sole trader or independently through limited company status) based in India. These are not processors per se but actual individuals working for the UK based entity on a contractor basis. Will SCCs need to be in place given the recipients are "contractors" of the UK entity? Or would it be deemed that the sole traders or contractors are part of the UK based entity therefore no SCCs are required?
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