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HL Chronicle of Data Protection Privacy & Information Security News & Trends

Tag Archives: international transfers

Posted in International/EU Privacy

Spain changes the paradigm of international transfers of personal data allowing Spanish data processors to be “exporters” under the Standard Contractual Clauses for the Transfer of Data

The Spanish Data Protection Authority (SDPA) has established new procedures that allow data processors (not data controllers) based in Spain to obtain authorizations for transferring data processed on behalf of their customers (the data controllers) to sub-processors based in Third Countries that are not deemed to have an adequate level of protection for personal data. In addition, data processors can enter into Standard Contractual Clauses with their sub-processors. Previously in Spain, data controllers had to enter into Standard Contractual Clauses with each of their data processors’ sub-processors in Third Countries and data controllers had to obtain authorizations from the SDPA for such transfers.