In this letter to the European Data Protection Board, ACCIS is thankful for the draft guidance offered on the “additional measures” – to be put in place alongside SCCs – for international data transfers. Overall, the recommendations as they stand appear to however rule out many simple and commonplace transfers which carry a minimal degree of risk for data subjects. An alternative approach would be to publish clearer guidance about specific jurisdictions – particularly those, such as the United States, where many organisations are likely to be transferring data.