After signing SCCs with a non-adequate vendor, a controller skips any transfer impact assessment because “the clauses are Commission-approved.” What step is still expected?
Select an answer to reveal the explanation.
Short Explanation
Commission-approved SCCs are a strong starting kit, not a magic force field. You still walk the destination’s legal landscape—who can demand data, what redress exists—and write down whether the clauses actually hold. Skipping that transfer impact thinking because the template looks official leaves a gap.
Full Explanation
EDPB guidance following Schrems II expects exporters using SCCs to assess the third country’s legal framework and practices that could impinge on the contractual safeguards, and to adopt supplementary measures where needed. Commission approval of the SCC text does not replace that case-specific effectiveness analysis. Marketing claims, obsolete Safe Harbor references, or unrelated filings do not substitute for a documented transfer impact assessment.