On March 5, 2020, the Danish Supervisory Authority (“Datatilsynet”) issued a guidance document in which it clarifies how companies should process the personal data of their employees in the context of the coronavirus (“COVID-19”) crisis (see here, in Danish). This follows the publication of a similar guidance by the Italian Supervisory Authority (“Garante”) (see

On December 11, 2019, the European Data Protection Board (“EDPB”) published the final text of the standard clauses adopted by the Danish Supervisory Authority (Datatilsynet, hereafter “Danish SA”) pursuant to Article 28(8) of the General Data Protection Regulation (“GDPR”).  The Danish clauses are now accessible on the EDPB’s register of decisions taken by Supervisory Authorities.  The Danish clauses serve as a standard data processing agreement that controllers and processors may choose to adopt to fulfill the requirements of Article 28(3) and (4) of the GDPR.  However, note that these SCCs are not standard data protection clauses under Article 46(2)(c) or (d) of the GDPR, and as such, cannot serve as a valid legal mechanism to transfer personal data outside the European Economic Area (“EEA”).

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