FEDMA answer to the EDPB consultation on Guidelines 04/201 on codes of conduct as tools for international transfers
The European Data Protection Board published a consultation on their draft Guidelines 04/2021 on codes of conduct as tools for transfers. FEDMA is developing a transnational GDPR Code of Conduct and it would be interesting if this Code could serve as a basis for transfer to third countries. We therefore thank the EDPB for this opportunity and are providing the following feedback:
- Encouraging transnational codes over national codes
- Uncertain benefits for Code owners
- Members to the Code need more procedural and legal certainty
- Code owners need clear and exhaustive requirements
- SA competence for accrediting the monitoring body
- Appropriate requirements for the monitoring bodies
- Codes, as tools for safe transfer, will be very few
Read the full response here.
