Dear Laura

 

I smiled to see your question, as I’m thinking about our international agent agreements currently and struggling with this too. One of my basic issues is that all the references to international transfers are about transfer TO the third country, and some of our information flow is inwards or both ways. Solicitors have inserted data controller and data processor clauses in the agent agreements but suggest the MCCs are needed too (both the controller-controller and controller-processor ones), but I don’t feel they properly represent the data flows and are a bit heavy. I too wondered if we could rely on necessary for entering contract, or consent, as these are agreements for introduction of potential students to us by agents.

 

Kind regards

Anne

 

 

University of Lincoln

Dr Anne Jolly | Information Compliance Officer

Secretariat
University of Lincoln, Brayford Pool, Lincoln, Lincolnshire, LN6 7TS
tel: +44 (0)1522 886685

staff profile  |  lincoln.ac.uk

 

 

 

 

 

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Laura Jones
Sent: 26 January 2018 08:46
To: [log in to unmask]
Subject: [data-protection] Transfer of Personal Data to International Universities

 

Hello All,

 

I wondered if anyone has started reviewing their international transfer arrangements? In particular, we’ve been reviewing the exchange of student data with our international partner universities for example where our student attends a placement or whether we validate an award delivered by another university.

 

We have a number of non-EU partner university and are considering negotiating the MCCs (where we don’t already have them).

 

I did consider whether we could rely on the derogations that the transfer is necessary for the performance of a contract or with the consent of the student. However, I note the GDPR provides that these derogations aren’t available to a public authority in the performance of its public task. I’ve taken the view that this would cover the provision of higher education in the context of placements and validation awards.

 

Are others taking the same approach and implementing the MCCs in these contexts?

 

Best wishes,

 

Laura

 

Laura Jones| Solicitor | Information Law

Legal Services|The Manchester Metropolitan University | Room 215 | All Saints| Oxford Road |

Manchester | M15 6BH

 

Email: [log in to unmask]

Telephone: 0161 247 3406

 

 

 

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