We thank the European Data Protection Board for granting stakeholders the opportunity to offer comments on the Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data.
Our joint feedback has been drafted from our viewpoint as an organisation that specialises in the development and monitoring of codes of conduct based on Articles 40-41 GDPR, and our role in the EU Cloud Code of Conduct as a widely adopted Code of Conduct pursuant to Article 40 GDPR. While the official approval of the current Code by the European Data Protection Board (EDPB) is pending, the EU Cloud Code of Conduct General Assembly already started the creation of a new module to the Code for transferring personal data outside of the EU in line with Article 46 GDPR.
Consequently, the comments are highly focused on our expertise within the ecosphere of third country transfers and the relevant facets of these Recommendations. Our comments should be read in this light, and notwithstanding broader comments by other stakeholders.