Exploring the EDPB’s guidelines on data transfers

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In a piece for the European Law Blog, Wilson Sonsini Goodrich & Rosati Senior Privacy Counsel Christopher Kuner likens the interplay between territorial scope and data transfer rules to an “awkward secret.� The European Data Protection Supervisor’s recently adopted guidelines are the first time DPAs have sounded off on the topic, which Kuner said is of “significant importance.� He looks at the guidelines, saying they are “unclear on some important points and allow gaps in protection,� and offers ways to provide “consistency and clarity.�
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