What the FAQ: Deciphering the European Commission Guidance on the New SCCs

Ahead of the year-end deadline for replacing the old standard contractual clauses (SCCs) with new modules, many organizations are still struggling to transition their legacy arrangements for a variety of reasons, including confusion around the paradigm shift that the new SCCs represent. To help organizations navigate the confusion, in May 2022 the European Commission published practical guidance (FAQs) on the use of the new SCCs. In this guest article, Squire Patton Boggs attorneys Diletta De Cicco and Charles Helleputte parse critical aspects of the FAQs, offering advice on how to interpret provisions that are unclear, identifying those of little real utility and providing practical insights regarding matters on which the FAQs are silent. See our two-part series on personal data transfers after year zero: “Are the New SCCs a Paradigm Shift?” (Jun. 30, 2021); “A More Appealing Set of EDPB Recommendations?” (Jul. 14, 2021).

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