We welcome the European Commission public consultation period on the Draft implementing decision and its Annex to discuss the standard contractual clauses (SCCs) for transferring personal data to non-EU countries as this is an important issue and an opportunity for stakeholders across all industries to provide input. Please find attached our detailed Position Paper.
EU consultation
Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries
58 submissions from 57 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 148 submissions on this file. Shown here: the 58 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
45 submissions from industry — companies and their trade associations — against 4 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 11.3 industry submissions for every one from civil society.
Industry 45Civil society 4Public authorities, academia, other 9
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
- 24 of 57
- in the EU Register
- 165
- full-time lobbying staff
- €22.1M+
- declared costs a year
- 154
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 10 Dec 2020 — it ran from 12 Nov 2020.
- Policy area
- Justice (DG JUST)
- Where it stands
- Awaiting adoption
How it got here
- Dec impl draft10 Dec 2020
Also on the Commission’s pipeline for this file, with no date recorded: Dec impl.
Showing 25 of 58 submissions.
The Confederation of Swedish Enterprise welcomes these new Standard Contracual Clauses, SCCs, in particular since the old SCCs only addressed two data flow scenarios: an EU-based controller exporting data outside of the EU to other controllers, or to processors.
The Software & Information Industry Association (SIIA) welcomes the opportunity to provide feedback regarding the European Commission's draft implementing decision on standard contractual clauses for the transfer of personal data to third countries.
DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…
Transfer of personal data within the European Economic Area (EEA) and to third countries is an significant part of our European digitalised and smart economy. Therefore, we highly welcome the European Commission’s approach to implement new Standard Contractual Clauses (SCC) for the transfer of personal data to third countries.
AFME welcomes the opportunity to provide comments on the European Commission Standard Contractual Clauses (SCCs) for transferring personal data to non-EU countries. Businesses from the financial services sector of all sizes rely on SCCs for data transfers that are essential to their activities.
Dear Sirs or Madams, please find attached the Response to public consultation on EU standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation 2016/679 of the European Parliament and of the Council of the Federal Association of Company Lawyers of Germany (Bundesverband der Unternehmensjuristen - BUJ). The statement is given by the expert group on data protection.
SIFMA welcomes the opportunity to provide comments on the European Commission Standard Contractual Clauses (SCCs) for transferring personal data to non-EU countries. Businesses from the financial services sector of all sizes rely on SCCs for data transfers that are essential to their activities.
DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…
COCIR remains committed to working with the EU institutions and relevant stakeholders to create a clear robust and futureproof framework for transfers of personal data to third countries, in full respect of the fundamental rights and freedoms of EU citizens. Please find our comments in attached document.
The attached comments on the Commission roadmap on standard contractual clauses (SCCs) for the transfer of data to third countries pursuant to Regulation (EU) 2016/679 (Implementing Decision) are being submitted jointly by the National Retail Federation (NRF), headquartered in the United States, and EuroCommerce, headquartered in Brussels, which is submitting the identical set of comments in parallel to this…
Dear Madam, Dear Sir, This Memorandum was resubmitted on 11 November 2020 as evidence of the feasibility and practicability of the measures enumerated in Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data which were were issued by the EDPB.
CN
Conseil National du Numérique
· · filed 10 Dec 2020 · source
On 12 November 2020, the Commission consulted the Implementing Decision aimed at ensuring compliance with the requirements of Regulation (EU) 2016/679 as regards the transfer of personal data to a third country [1]. This is in response to the judgment of the Court of Justice of the European Union (CJEU) Schrems II [2] of 20 July 2020, which invalidates the so-called Privacy Shield Agreement [3].
Filed in French · English published by the European Commission
Dear Sir or Madam, Please find attached ACT | The App Association's comments to Standard contractual clauses – Commission implementing decision on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. Sincerely, [name removed] ACT | The App Association
FEDMA thanks the European Commission for the opportunity to provide comments on the draft standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. FEDMA will also provide feedback to the EDPB on their recommendations 1/2020.
The following comments on the Commission roadmap on standard contractual clauses (SCCs) for the transfer of data to third countries pursuant to Regulation (EU) 2016/679 (Implementing Decision) are being submitted jointly by EuroCommerce, headquartered in Brussels, and the National Retail Federation (NRF), headquartered in the United States, which will be submitting the identical set of comments in parallel to this…
TrustArc welcomes the opportunity provided to share it’s views on the new SCCs and respectfully submits the comments attached for consideration ahead of the final decision. These include the request to confirm the scope of application of the new SCCs, especially in relation to Article 3(2) GDPR, the need to align the terminology used between the GDPR and the new SCCs, as well as the possibility to maintain up to…
We appreciate the chance to provide comments on the new standard data protection clauses for the transfer of personal data to third countries pursuant to Article 46 GDPR. We acknowledge the great value of the updated framework, which will help companies when relying on third country transfers and hope our detailed comments may contribute to the further enhancement of the SDPC.
CCIA welcomes the timely publication of the draft Standard Contractual Clauses (‘SCC’) implementing decision. We generally support the current draft and believe it will pave the way towards greater legal certainty for the vast majority of data transfers outside the European Economic Area.
Dear Madams and Sirs, Please find attached CrowdStrike's feedback to the draft standard contractual clauses for transferring personal data to non-EU countries (Draft implementing decision incl. Annex). We would welcome the opportunity to discuss these matters in more detail. Sincerely Dr. [name removed]/E on behalf of CrowdStrike Privacy and Policy Team
Dear Sir or Madam! Please find attached our comments to Standard contractual clauses – Annex to the Commission implementing decision on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council. Yours faithfully, dr. [name removed], attorney-at-law, Head of Legal Services dr. Nóra Takács, attorney-at-law dr.
CISPE RESPONSE TO THE DRAFT STANDARD CONTRACTUAL CLAUSES PURSUANT TO REGULATION (EU) 2016/679 (“GDPR”) 1. Presentation of CISPE Cloud Infrastructure Services Providers in Europe (CISPE) is a non-profit association that focuses on developing greater understanding and promoting the use of cloud infrastructure services in Europe. Members based in 14 EU Member States range from SMEs to large multinationals.
In an increasingly international and digitalised context, and in particular in the run-up to Brexit, it is essential for businesses to rapidly have a stable, secure and effective legal solution that allows for the maintenance and continuity of transfers of personal data outside the EU, especially as standard contractual clauses remain the most used tool by companies for transfers outside the EU.
Filed in French · English published by the European Commission
Access Now welcomes the opportunity to provide feedback to the draft standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, through the public consultation organised by the European Commission. Our detailed comments can be found attached. We remain available for any questions you may have.
AFEP member companies fully support the ambitions of the European Commission to enforce its personal data protection standards in favour of its European citizens, consumers, or employees. However, this must go hand in hand with smooth flows of data worldwide and no unnecessary and disproportionate companies’ administrative and financial constraints.
techUK would like to thank the European Commission for the opportunity to provide feedback on the draft implementing act for new standard contractual clauses (SCCs) for transferring personal data to non-EU countries.
Dear ladies and gentlemen, We welcome the opportunity to comment on the existing drafts for the implementing decision on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as set forth in the attached document. Kind regards [name removed] Bundesverband Digitale Wirtschaft e. V. (BVDW)
The decision of the Court of Justice of the European Union (CJEU) of 16 July 2020 on Privacy Shield reiterated the need for a high level of data protection requirements for citizens and economic operators, involving a review of data regimes vis-à-vis third countries.
Filed in French · English published by the European Commission
The decision of the Court of Justice of the European Union (CJEU) of 16 July 2020 on Privacy Shield reiterated the need for a high level of data protection requirements for citizens and economic operators, involving a review of data regimes vis-à-vis third countries.
Filed in French · English published by the European Commission
Dear Commissions, William Fry welcomes the proposal for the Draft SCCs as set out in the Draft Decision. We recognise that they are a response to changes in the regulatory framework around data protection compliance.
The decision of the Court of Justice of the European Union (CJEU) of 16 July 2020 on Privacy Shield reiterated the need for a high level of data protection requirements for citizens and economic operators, involving a review of data regimes vis-à-vis third countries.
Filed in French · English published by the European Commission
BSA | The Software Alliance (“BSA”), the leading advocate for the global software industry, welcomes the opportunity to provide feedback on the European Commission’s draft new standard contractual clauses (“SCCs”) for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679. We respectfully submit the comments attached in response to the Commission’s consultation on the New SCCs.
The German Insurance industry welcomes the EC’s efforts to provide practical solutions for the transfer of personal data to third countries. While the draft implementation act and the updated SCCs are a great step forward, certain adjustments appear necessary and sensible.
BIPAR thanks the European Commission for the opportunity to comment on its draft implementing decision on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 and its annex. Please find attached BIPAR comments. We remain at the Commission ‘s disposal for any questions on the attached document Kind regards, [name removed] Director Av.
EACA welcomes the opportunity to provide feedback on the Draft Implementing Decision (Ref: Ares(2020)6654686) and Annex (Ref: Ares(2020)665468) on standard contractual clauses for the transfer of personal data to third countries pursuant to the General Data Protection Regulation (GDPR).
DC
Danish Chamber of Commerce
· · filed 10 Dec 2020 · source
Initially we would like to thank the Commission for taking the initiative to revise the existing SCCs. New standard contracts have long been needed and it is of enormous importance that the Com-mission focuses on creating tools that in practice enable data transfer to the US until we hopefully very soon will have a new EU-US agreement to replace the Privacy Shield agreement.
We welcome the European Commission’s public consultation on draft implementing decision as it gives all interested business actors an opportunity to discuss the standard contractual clauses for transferring personal data to non-EU countries which are a highly important notion that cannot remain a side-issue, but on the contrary, should be thoroughly scrutinised in order to ensure an effective transfer of data.
Dear Sir or Madam, Please find our detailed comments on the draft standard contractual clauses for transferring personal data to non-EU countries (implementing act) in attachment. We remain at your disposal should you have questions or comments. Kind regards, [name removed] on behalf of ITI
We welcome the opportunity to provide input and comments. The issues highlighted by the Schrems II ruling and the subsequent European Data Protection Board communications on the matter have potentially far reaching implications for many industries in the digital economy, including the IT Services industry, which rely on the export and import of Personal Data. Please find attached our comments.
DA
DIFC Authority
· · filed 10 Dec 2020 · source
As an attendee of the SCC workshop held in Brussels in September 2019, I am pleased to see that a lot of that conversation was taken on board and written into the draft SCCs. The Schrems II decision further called into question the effectiveness of the SCCs or indeed any appropriate safeguard mechanism or derogation as they all, in principle, attempt to create an environment of adequacy where one does not exist in…
BEUC thanks the Commission for the opportunity to comment on the draft standard contractual clauses for transferring personal data to non-EU countries. In attachment our response. We remain available for answering any questions the Commission may have. BEUC's Digital Team
IATA Response to the European Commission consultation on its Implementing Decision on standard contractual clauses (“SCCs”) for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council - See attached
Dear ladies and gentlemen, Boehringer Ingelheim welcomes the opportunity to provide feedback regarding the European Commission’s consultation regarding a draft implementing decision on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as set forth in the atteched document.
Prosus is thankful for the opportunity to provide feedback on the revision of the standard contractual clauses for the transfer of personal data to third countries. In summary, we would like to raise the following points. For more details, please see our attached comments. 1.
Dear Commission, Please find attached our feedback on the draft Data protection - standard contractual clauses for transferring personal data to non-EU countries (implementing act). Best regards, [name removed] and [name removed] on behalf of the Norwegian Institute of Public Health (NIPH)
JE
Japan Electronics and Information Technology Industries Association
· · filed 10 Dec 2020 · source
Feedback to Draft implementing decision on SCC and Annex December 10, 2020 Japan Electronics and Information Technology Industries Association (JEITA) Following the publication of Draft Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 and its Annex, JEITA, the Japan Electronics and Information Technology…
Established in Dublin in 1990, the Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies in the world. ACCIS brings together 42 members across 28 European countries and 10 associate and affiliate members from all other continents. Please find our feedback on this consultation in the attached PDF document. Thank you for your attention.
South-West metals is an employer’s association based in Baden-Württemberg/Germany that reppresents car manufacturers and the supporting industry, companies that operate in the fields of Electronical and/or mechanical engineering as well as as companies that operate in medical and environmental engineering. Approximate 980.000 employees are part of this industry in Baden-Württemberg.
Filed in German · English published by the European Commission
The European Association of Co-operative Banks (EACB) represents, promotes and defends the common interests of its 27 member institutions and of cooperative banks, with regard to banking as well as to co-operative legislation. Please find the EACB feedback on this consultation in the attached PDF document. Thank you for your attention.
TT
The Thinking Watermill Society
· · filed 9 Dec 2020 · source
The Thinking Watermill Society (https://thethinkingwatermill.com) is a non profit organization focused inter alia on technology innovation. The new standard contractual clauses for data transfer outside EU require from the parties a high degree of awareness and technical preparation.
The Association of Medical Ethics Committees in Germany represents all Medical Ethics Committees in Germany that are involved in the assessment of clinical trials with medicinal products, medical devices or radiation exposure. We appreciate that the European Commission has initiated a public consultation on the draft standard contractual clauses (SCC) for the transfer of personal data to third countries.
There are some operational issues with the current structure and language in the draft Standard Contractual Clauses contained in the Annex to the Draft Commission Implementing Decision. As my comments are somewhat detailed and specific, they would not fit within the character limit of this form. I have compiled my observations and recommendations in a letter attached to this comment.
CLEPA, the European Association of Automotive Suppliers, is providing its feedback on the draft implementing act on SCC for transferring personal data to third countries. Please refer to the attached document for details.
VG
Viega Group
· · filed 7 Dec 2020 · source
On the Commission Implementation Decision: No feedback On the Annex: Section II, Clause 1, Module One, paragraph 1.7: The onwards transfer under sub-paragraph iii is not in line with the GDPR: Appropriate measures are concluded in Articles 45 to 50 and an agreement is not part of this.
Greetings [name removed] Global Market (ADGM) Office of Data Protection, We appreciates the opportunity provide the European Commission with feedback regarding the published initiative for the proposed standard contractual clauses for transferring personal data to non-EU countries. Please see the attachment. Best Regards
The full detail of our feedback and proposed amendments to the current wording are included in the attached pdf but, in summary, we believe that the SCCs should refer more-clearly to the specific obligation under GDPR Article 27 to appoint a Representative in the EEA, because: • SCCs will be used by most companies which require a Representative: Companies which are required to appoint a Representative are likely to…
We have attached our comments in a document but for interest the following are a summary of them (full document needed for context): General 1. There seems no need to prevent the continuance of reliance on the existing SCCs for only one year. The one year period set out here could be amended to allow for indefinite reliance, or, say, five years.
GH
Gloucestershire Hospitals NHS Foundation Trust
· · filed 16 Nov 2020 · source
Under A. List of Parties in Annex 1 is a section for "Activities relevant to the data transferred...". It is not clear what is expected here as this does not relate to the identity of the parties. "See B - Description of the Transfer" would seem appropriate in all cases so the section is redundant Is it appropriate to require that the applicable law forum and jursidiction must be an EU state even for processor to…
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.