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The Article 29 Working Party has released its working draft on standard contractual clauses for the transfer of personal data from an EU data processor to a non-EU data sub-processor. While there is currently a decision on standard contractual clauses for the transfer of personal data to processors in third countries, the Article 29 Working Party says it’s appropriate to work on a new set of contractual clauses from an EU data processor to a non-EU data sub-processor. The working document aims to advise the commission should it one day consider amending or supplementing existing model clauses currently in place under the Data Protection Directive.
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