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The following comments on the European Data Protection Board (EDPB) draft Recommendations on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data as adopted 10 November 2020 (Draft Recommendations) are being submitted jointly by EuroCommerce, headquartered in Brussels, and the National Retail Federation (NRF), headquartered in the United States, which will be submitting the identical set of comments in parallel to this submission.
As representatives of the retail and wholesale industry engaged in cross-border data flows and on behalf of our members, we welcome the efforts of the EDPB to draft recommendations with respect to supplementary measures required for transfers of personal data to third countries outside the EU, especially in light of this year’s Schrems II ruling by the European Court of Justice (CJEU). We believe that a framework ensuring both protection of personal data and the maintenance of transatlantic data flows is an essential factor in the proper functioning of the global retail economy. Economic recovery after the present COVID crisis will in large part be driven by data, which is a vital element of retail and wholesale businesses on both sides of the Atlantic, whether as players in both markets needing to transfer sales, supply or personnel data freely between their operations in various territories, or as clients of data processors or cloud providers located in the other market. We therefore welcome the EDPB’s efforts in provide clarity on parties’ obligations post-Schrems II and allow international data transfers to continue while maintaining the high level of protection under EU law.
This important work on Draft Recommendations is closely related to the European Commission’s work modernising Standard Contractual Clauses (SCCs), including in light of Schrems II, and it will be important – in order to avoid legal uncertainty and confusion – that the EDPB’s adopted recommendations are fully in line with the modernised SCCs.
Read moreThe following comments on the Commission roadmap on standard contractual clauses (SCCs) for the transfer of data to third countries pursuant to Regulation (EU) 2016/679 (Implementing Decision) are being submitted jointly by EuroCommerce, headquartered in Brussels, and the National Retail Federation (NRF), headquartered in the United States, which will be submitting the identical set of comments in parallel to this submission.
As representatives of the retail industry engaged in cross-border data flows and on behalf of our members, we welcome the efforts of the Commission to establish a modernised set of SCCs to enable transfers of personal data to third countries outside the EU that have not yet received a finding of adequacy, especially in light of this year’s Schrems II ruling by the European Court of Justice (CJEU). We believe that a framework ensuring both protection of personal data and the maintenance of transatlantic data flows is an essential factor in the proper functioning of the global retail economy. Economic recovery after the present COVID crisis will in large part be driven by data, which is a vital element of retail and wholesale businesses on both sides of the Atlantic, whether as players in both markets needing to transfer sales, supply or personnel data freely between their operations in various territories, or as clients of data processors or cloud providers located in the other market. We therefore welcome the Commission’s efforts in updating the SCCs and seeking to provide a mechanism to allow international data transfers to continue while maintaining the high level of protection under EU law.
This important work on SCCs is closely related to the EDPB recommendations regarding additional safeguards, and it will be important, in order to avoid legal uncertainty and confusion that those EDPB recommendations are fully in line with the modernised SCCs.
Read moreEuroCommerce welcomes the opportunity to provide comments on the European Data Protection Board’s (“EDPB“) Guidelines 02/2021 on Virtual Voice Assistants (the “Guidelines”). EuroCommerce appreciates the EDPB’s efforts to provide guidelines for Virtual Voice Assistants (“VVA“) with the aim to guarantee adequate privacy protection for users as the service is available for a vast majority of people when using for example their smartphones. In light of the foregoing, EuroCommerce believes that it is important that such guidelines remain sufficiently open and flexible so that they can take into account the specific characteristics of the different voice service architectures and the rapid technological developments in the VVA sector. In this regard, the legal framework should allow for use of VVA solutions in a way that is not to the detriment of digital innovation as well as European businesses’ competitiveness on the global market.
Below we summarise our key points and proposals and detailed comments which we hope will be helpful when finalising the Guidelines. We would be more than pleased to discuss these issues further with the EDPB should you have any questions regarding our comments.
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