On 7 June 2021, the European Commission published long awaited modernized standard contractual clauses (“SCCs”) under the General Data Protection Regulation (“GDPR”) for data transfers from controllers or processors in the European Union/European Economic Area (“EU/EEA”) (or otherwise subject to the GDPR) to controllers or processors established outside the EU/EEA.
As a global privacy leader, Comscore seeks to provide its clients the tools and information they need to make informed decisions. Comscore is performing a comprehensive review of the new SCCs to understand the implications of the new SCCs, assess the necessary updates required for contracts, and collaborate with its clients to implement those updates, where necessary. Comscore will also be reviewing anticipated forthcoming guidance from EU/EEA authorities regarding implementation of the new SCCs.
As part of Comscore’s review of data transfer mechanisms in July 2020, Comscore updated its Data Protection Addendum and replaced the reliance on Privacy Shield certification with the appropriate SCCs. For more information about the steps Comscore took at that time, please read the Roadmap for Safeguarding Continuity in EU-U.S. Data Transfers for Comscore Customers.
At this time, while undertaking review of the SCCs and awaiting additional guidance, Comscore will continue to rely on the legacy SCCs, as applicable, in accordance with the EU Commission’s determination that parties may continue to use the legacy SCCs as a data transfer mechanism for contracts signed before 27 September 2021. Comscore’s completed legacy SCC document includes Comscore’s additional safeguards, which are also detailed at https://www.comscore.com/About/Privacy/Security.
For contracts signed any time before 27 September 2021 that rely on the legacy SCCs as a data transfer mechanism, Comscore may also continue to rely on the legacy SCCs for that purpose until 27 December 2022. Comscore will strive to work with clients during that period to make necessary updates.
If you have any questions, please do not hesitate to reach out to Comscore at GDPR@comscore.com.