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.