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Would a UK-based controller intending to appoint another UK-based company as a processor (who will need to appoint a sub-processor outside the UK) need to be party to the standard contractual clauses between our processor and their sub-processor, or can we rely on article 28(4) of the UK GDPR?

Anonymous (Private practice)

Q:
We are a UK-based data controller and intend to appoint another UK-based company to processor personal data on our behalf. Under the proposed data processing agreement, the processor may appoint a sub-processor based outside the EEA in a country for which there is no adequacy decision. In the case of such a cross-border transfer of personal data, the processor would enter the new EU processor to processor standard contractual clauses. Would we, as the data controller, need to be party to the SCCs between our processor and their sub-processor, or can we rely on article 28 (4) of the UK GDPR?

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End of Document
Resource ID a-133-9737
© 2024 Thomson Reuters. All rights reserved.
Date published
18 May 2022
Resource Type Ask
Jurisdiction
  • United Kingdom
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