In this letter to European Commissioner Reynders and European Data Protection Board (EDPB) Chairwoman Dr Jelinek, ACCIS and other leading European trade associations in the area of financial services express concern about the risks arising from the CJEU Schrems II ruling and call for urgent legal certainty, to ensure that European companies can carry out their business activities. The associations specifically welcome the EDPB’s intention to present guidance on the “additional measures” to be put in place alongside Standard Contractual Clauses and propose a number of recommendations in that regard.

The associations also urge the EDPB and the national Data Protection Authorities not to proceed with sanctions against companies until the EDPB guidance has been issued and a sufficient period of time has elapsed to enable businesses to implement the relevant procedures.