Deadline for switching to new SSCs for data transfer of 27 December, 2022

15 Nov 2022

EC new standard contractual clauses (SCC) for data transfer to third countries were adopted in June 2021. Institutions that transfer personal data to third countries are required to replace the current clauses, based on the old rules, with the new updated templates published by the EC by 27 December, 2022. A range of measures are required for controllers or processors to implement the SCCs correctly, such as selecting the appropriate clause module.

Why do I need to change the SCCs I am using at the moment?

  • From 27 December onwards, use of the “old SCCs”, which are those that the EC issued even before the GDPR was in force, will be a breach of data protection laws.

What needs to be done by 27 December

  • A documented review of all “potential data transfers”, taking into account transfer chains;
  • A review of lawfulness of transfer to a particular third country;
  • Insertion of additional wording in the new SCCs to account for business needs.

For more information on the new SCCs or data transfer to third countries, contact TKP at