You’ll almost certainly need to enter into Article 46(2)(c) model clauses, as the Commission has not made a finding of adequacy in respect of Australia.
And we should all get used to needing to know a heck of a lot more about international transfers, given the way Brexit is likely to play out.
Sent from my iPhone
> On 7 Jan 2020, at 16:42, Danny Budzak <[log in to unmask]> wrote:
>
> Happy New Year all,
>
> I am sure I should know the answer to this, perhaps too many mince pies in recent weeks.
>
> Our HR department is considering procuring an e-learning system which is cloud based, software-as-a-service.
>
> All of the data processing seems to take place in Australia. I can't find anything which specifically references Australia in relation to GDPR. It would not be much personal data - name, email and records of course completed.
>
> Any thoughts?
>
> [There is a separate question of sustainability - do we really need to send data on a 24,000 mile round trip?- I am looking forward to reading Mike Berners Lee 'How Bad are Bananas - the Carbon Footprint of Everything']
>
> Danny
>
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