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On of the most common basis for legally transferring personal data from the EU to the USA, India or China is an agreement based on the Standard Contractual Clauses developed by the European Commission (SCC).
On the basis of the CJEU judgment in the Schrems II case, on 4 June 2021, the European Commission adopted a new set of SCC to ensure compliance with new legislation. Consequently, all old SCC must be replaced with new ones by 27 December 2022. In the case of large enterprises, this means hundreds and sometimes thousands of contracts having to be signed in line with the new version!
In view of the current transition period ending 27 December 2022, parties that concluded contracts before 27 June 2021 may continue to use the old SCC. Still, they are required to carry out an additional adequacy assessment and implement any necessary supplementary measures as referred to in the EDPB 01/2020 recommendations.
After 27 December 2022, all data transfers based on old SCC must be changed to the new SCC.
What is the scope of the changes and what implementation measures should be taken? In the attached alert, you can find a summary of the most important information regarding changes in the transfer of personal data outside the EU.
From 25 May 2018 the General Data Protection Regulation (GDPR) applies in Poland and other European Union countries. We would therefore like to give you several details on the subject of how DZP processes personal data.
The administrator of the personal data is Domański Zakrzewski Palinka Sp.k. (“DZP”; address: Rondo ONZ 1, 00-124 Warszawa). Data are processed for contact purposes and to impart information on changes to provisions and authority practices and on other issues, including events concerning day-to-day legal, economic and cultural issues, inter alia, by sending DZP newsletters. The above is carried out on the basis of legitimate interests, i.e. in accordance with art. 6(1)(f) of the GDPR. Data can also be processed where necessary for the conclusion or performance of a contract and for compliance with a legal obligation to which DZP is subject, i.e. pursuant to art. 6(1)(b) and (c) of the GDPR. Data can be transferred to entities with whose help DZP achieves the indicated aims, including entities maintaining IT infrastructure. Giving data is voluntary and in contractual relations is a requirement for concluding and performing a contract. It is possible to object to data processing, request access to, rectification and erasure of personal data or restriction of processing and data portability. Data are kept until an objection is made, and in contractual relations – throughout the term of the contract and thereafter for a period specified in provisions on archiving and limitations period for claims. Anyone has the right to file a complaint with the President of the Personal Data Protection Office. Questions concerning privacy at DZP can be sent to DZP’s Data Protection Inspector, Macieja Maciejewskiego, at: email@example.com.
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