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Top 5 Takeaways from European Commission SCCs for Schrems II Compliant International Data Transfer

Anonos - Lawful Borderless Data

Anonos - Lawful Borderless Data

Schrems II SCC Annex II Anonos Data Embassy Technology

Schrems II SCC Annex II Anonos Data Embassy Technology

Schrems II Webinar: SCC & EDPB Requirements for Technical Measures (Presented by Anonos)

Schrems II Webinar: SCC & EDPB Requirements for Technical Measures (Presented by Anonos)

How To Implement Supplementary Measures by Anonos (Infographic)

How To Implement Supplementary Measures by Anonos (Infographic)

BRUSSELS, BELGIUM, June 9, 2021 / -- Anonos, a leading provider of state-of-the-art data enablement and protection technology, has today released its ‘Top 5 Takeaways’ surrounding the publication of the much anticipated new Standard Contractual Clauses (SCCs) from the European Commission (EC).

The EC has published the new SCCs to help businesses continue with the legal transfer and processing of international data. When making the announcement, Justice Commissioner Didier Reynders highlighted the need to “guarantee the highest possible level of ‘legal security’ for GDPR-compliant international data transfers.”

Anonos is today sharing the ‘Top 5 Takeaways’ required for businesses to continue using SCCs to maintain international data flow:

1) New as well as existing SCCs require "Surveillance Proof" supplementary measures - This means businesses cannot wait to migrate to new SCCs and must immediately implement “Surveillance Proof” supplementary measures for processing using SCCs to be lawful. Descriptions of these supplementary measures must be precise and specific and not provided in general terms.

2) GDPR Pseudonymisation is the technical control that protects data during processing - This means if a business desires practical data use protections (not just for when storing or transmitting data) GDPR Pseudonymisation is the technical means to protect data in use. Encryption and prior data obscuring techniques like static tokenisation, key-coding and masking will NOT protect data up to Schrems II standards during processing.

3) Data subjects are third-party beneficiaries and may enforce SCCs in the EU - This means EU data subjects can sue your organisation to enforce SCCs in EU courts. Businesses and their partners must therefore take action to show transparency and trust by moving beyond policies and contracts and enforcing new technical controls.

4) All parties in data supply chains are jointly and severally liable for failures to comply - This means data subjects can recover losses directly from businesses not only for their failure but also the failure of other parties in the data supply chain. From a data subject's perspective, businesses are now responsible for compliance by all parties in the data supply chain.

5) Failure to implement Schrems II compliant safeguards can disrupt data supply chains - This means if downstream data supply chain parties do not have adequate safeguards, upstream data providers will discontinue data flow rather than damaging their own business.

Gary LaFever, CEO and General Counsel, Anonos, commented: “GDPR Pseudonymisation is the most effective measure to eliminate the risk of foreign government surveillance over personal data of EU subjects. Because it ‘pseudonymises’ personal data before leaving the EU, foreign governments cannot re-link the data to specific individuals as they do not have access to the additional details needed to do so. This transforms otherwise illegal cloud processing and remote access into lawful processing in compliance with Schrems II.”

Read the full article at:

Together with PwC, Paul Hastings and AContrario, Anonos is running a dedicated webinar on 22 June to discuss the key discussion points following the imminent and final Schrems II guidance expected from the European Data Protection Board, which over 2,000 people have already registered to attend.

Register for the Schrems II Webinar: SCC & EDPB Requirements for Technical Measures at

For more information on how to continue lawful processing of EU data in compliance with Schrems II and other global data sovereignty and localisation laws, join the Schrems II Linkedin Group with over 7,700 other members at

About Anonos:

Anonos’ state-of-the-art patented Data Embassy technology makes the impossible possible: It uniquely reconciles conflicts between maximising (i) data use, sharing and combining and (ii) data protection and privacy. Whether for AI or ML models or improving your data analytics solutions, you extract the most value from personal data with dynamic use cases. Why settle for outdated techniques protecting only static uses that deliver little value?

Let Anonos prove how our Data Embassy software can solve your most complex legal and data challenges to maximise data value without compromising accuracy or legal requirements. Learn more at

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