With the ruling from the German DPA yesterday, how do you all think this will affect major users of this program and its sister products, What do we need to do? For information we process Sensitive information as for Education purposes… HELP??
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With the ruling from the German DPA yesterday, how do you all think this will affect major users of this program and its sister products, What do we need to do? For information we process Sensitive information as for Education purposes… HELP??
HellenB
This page has a reasonable translation on it.
https://gdprhub.eu/index.php?title=BayLDA_-_LDA-1085.1-12159/20-IDV
MPenot
Helen,
thank you for this link, however this was not what I meant. I was referring to the the Baden-Württemberg authority publishing practical steps to amend your SCCs with.
They have 4 amendments which are as follows (I need to split them because of the word count):
Amendment to Annex Clause 4(f): informing affected persons not only when transmitting special categories of data, but with any data transmission (before or as soon as possible after the transmission) that their data will be transferred to a third country which does not have an adequate level of protection in the sense of the GDPR.
MPenot
continuation of the amendment list of the SCCs
Supplement to Annex Clause 5(d): to include obligations for the data importer to refrain against the disclosure of personal data to the respective authorities until the competent court sentences them to disclose such data.
Perry Perrott
MPenot Thank you I would appreciate the translation
MPenot
Perry this is a word document and I seem to not be able to attach it in here. Do you want to indicate a means of sending it to you?
MPenot
Make sure you are checking all your international data transfers,
send them the questionnaire that Max Schrems has put on his website to determine if they fall under FISA 702/ EO 12333.
If they do either choose a European solution, or determine if you fall under the 5 allowed use cases in the EDPB (draft) guidance for supplemental measures. Use SCCs with additional contactual, technical and organizational measures if possible.
The DPA “next door” to the Bavarian DPA you were mentioning (because Germany has 18 secular DPAs and 5 religious DPAs) namely Baden-Würthemberg has published a guidance paper with practical steps what to add to the SCCs. If you would like I can share a translation.
Figaro
I would love that, yes please! 🙂