Sullivan Willoughby Updates the Contractual Agreements and Rules for the Transfer of Personal Data

Sullivan Willoughby, a leading international law firm that offers a full range of legal services, having a large scale, specialized expertise, standard management system, international presence, and a well-known brand, as well as an explicit shared values-based culture of client service and professionalism, is pleased to announce the most important compliance procedures to take in light of the additional measures recommendations, as well as the major revisions made to the final version of the recommendations. If the level of protection is not generally comparable, businesses must determine whether additional technical, contractual, and/or organizational precautions are necessary.

A specific roadmap is presented within the recommendations to assist companies in assessing third parties and identifying and implementing the appropriate extra measures for the transfer of personal data:

• Understanding data transfers, mapping and evaluating data flows to third parties;
• Determining the tool a certain transfer is reliant on;
• Evaluating the efficiency of the transfer mechanism;
• Adopting and implementing appropriate supplemental measures;
• Taking additional formal procedural measures that are required;
• Reevaluating at regular intervals.

The first step in incorporating potential supplementary measures and new standard contractual clauses into data transfer agreements is to map all personal data transfers to identify the cases in which personal data is transferred, then evaluate the level of protection in the case of the third party to see if the transfer mechanism needs to be updated and additional safeguards introduced (e.g., technical measures such as encryption). As a result, it is essential to accelerate data mapping and transfer effect assessment initiatives, as well as develop clear priority strategies.

About Sullivan Willoughby

Sullivan Willoughby serves clients across a wide range of complex transactional, litigation, and regulatory concerns. We are known for our expertise in the energy, financial services, real estate, retail, and consumer products industries, as well as our outstanding experience in distinct areas of practice, including privacy and cybersecurity, intellectual property, environmental, mergers and acquisitions. Our full-service litigation business is one of the largest in the region, with special expertise in key markets. Companies, individuals, governments, and institutions from all industries that make up today’s global economy are among our clientele. We bring together multi-disciplinary teams with substantial industrial, legal, and strategic planning expertise to develop customized solutions that address current challenges while minimizing future risks.

About Sullivan Willoughby

We bring together multi-disciplinary teams with substantial industrial, legal, and strategic planning expertise to develop customized solutions that address current challenges while minimizing future risks. – sullivan-willoughby.com