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Europe Data Protection Digest | Privacy Commission, MOJ Execute New Transfer Approval Process Related reading: EDPB issues opinion casting doubt on legality of pay-or-consent models

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The Belgian Privacy Commission and Ministry of Justice have executed a protocol that puts in place a new approval process for data transfer agreements, the Field Fisher Waterhouse Privacy and Information Law Blog reports. The protocol “acknowledges that it is sometimes justified for data exporters to make (some) changes to the EU Model Clauses.” However, it creates some burden for EU Model Clauses in that, previously, no formal approval was required when the clauses were used in unaltered form, the report states, noting this has now changed.
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