Reminder – Old EU Standard Contract Clauses will not be compliant in the UK after 21 March 2024.

Background

As of 22 September 2022, the old EU Standard Contractual Clauses (SCCs) adopted in 2001 and 2010 by the European Commission ("the Old EU SCCs") could not be used for new contracts transferring personal data outside of the UK under the UK GDPR.

The deadline for moving away from the old EU SSCs for all contracts is 21 March 2024. After this date, the Old EU SCCs will no longer be compliant in the UK.

What do you need to know about the deadline?

If you have a contract where personal data is being transferred outside of the UK under the Old EU Standard Contract Clauses, you need to consider alternative means of achieving compliance with the cross-border transfer requirements by 21 March 2024.

This may mean replacing the Old EU SCCs with either of the tools now approved by the UK Government, namely the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the new EU Standard Contractual Clauses issued in June 2021 (UK Addendum).

The BHBIA’s Ethics & Compliance Committee provides guidance as general information for its members. It is not legal advice and should not be relied upon as such. Specific legal advice should be taken in relation to any specific legal problems or matters. Whilst every reasonable effort is made to ensure the information is accurate, no responsibility for its accuracy or for any consequences of relying on it is assumed by the BHBIA.