On the other hand, the fact that there are two sets of standard clauses available for controller-to-controller transfers and for controller-to processor transfers, one set of SCC's but none for processor-to-controller 'transfers' may indicate that this is not in fact regarded as a transfer.
Page 250 of the EU DP handbook contains the following interesting key-point at P250: "Ensuring the data subject’s rights are safeguarded when data are transferred outside the EU allows the protection afforded by EU law to follow the personal data originating in the EU."
Does this suggest a different approach to personal data NOT originating in the EU? E.g. Elbonian controller, EU processor. And post Brexit UK may equate to Elbonian.
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