By Tom Jackson
On November 26, 2014, the Article 29 Working Party adopted a working document setting out a cooperation procedure for issuing common opinions on contractual clauses considered as compliant with the EC Model Clauses (the “Working Document”). The Working Document sets out the framework for a procedure designed to streamline the process of obtaining the necessary approvals to transfer data outside the EEA. It introduces the concept of a “Lead DPA,” through whom an applicant company would be able to deal with a range of competent national authorities in order to gain a common opinion on the adequacy of its contractual clauses.
The publication of this Working Document serves as an indication that European data protection authorities recognize that the current system is burdensome and often time-consuming for companies seeking to transfer data outside the EEA. However, it remains to be seen when, or even if, the procedure proposed by the Working Party will be put into practice.
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