Hello colleagues,
We use the Model Contract Clauses as we find the legally binding instrument between public bodies very problematic - in most other European countries, universities are not public bodies. That's why we play it safe and use the Model Clauses.
Best wishes
Rena
______________________________
Dr Rena Gertz PC.dp
Data Protection Officer
Old College
University of Edinburgh
South Bridge
Edinburgh EH8 9YL
0131 6514114
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Emile Douilhet
Sent: 12 February 2019 10:30
To: [log in to unmask]
Subject: Re: [data-protection] Cross Border Data Flows for the purpose of research
Hello!
There are indeed ways of ensuring data can keep coming from the EU to the UK. There are two main ones for us:
- the most applicable one I believe is Standard Contractual Clauses at GDPR Article 46(1)(c) - a set of clauses inserted into a contract which allow for transfers between entities. We received a set of those clauses usable for all HE establishments, I am not sure if everyone did. This is where we are headed for such arrangements.
- a legally binding and enforceable instrument between public authorities or bodies under Article 46(1)(a), but, well, with Brexit looming such instruments are hard to establish.
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