Open Rights Group submission to the Information Commissioner’s Office – International Transfers Under the UK GDPR

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Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online. With over 20,000 active supporters, we are a grassroots organisation with local groups across the UK.

This is our answer to the Information Commissioner’s Office consultation regarding the proposed International Data Transfers Agreement (IDTA), Addendum to the EU Standard Contractual Clauses (SCC), and the International Transfers Risk Assessment Tool.

As a first, overarching consideration, we stress the importance of retaining consistency between these tools and the European Commission SCC as well as the EDPB “Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data”. We believe the ICO should have provided a comparison between the instruments they seek to implement and the relevant EU counterparts, as well as an explanatory note outlining the reasoning behind changes or peculiarities in the proposed documents. In the absence of such comparison, respondents to the consultation are likely

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