Schrems II – SCCs | FIS
This set of FAQs highlights the key topics addressed in the Schrems II judgment (the “Schrems II Judgment”) from the Court of Justice of the European Union (“CJEU”) to help our clients, partners and vendors understand our approach to the Schrems II Judgment.
This content presents a general overview of the Schrems II judgment and does not provide legal advice. It is imperative you seek independent legal advice to discuss the requirements applicable to your specific circumstances.
What is the Schrems II Judgment?
What is the significance of the Schrems II Judgement?
What is a direct consequence of Schrems II judgement?
In addition, the European Data Protection Board issued recommendations on “supplementary measures” that companies can implement, in addition to the SCCs, to safeguard the processing the personal data in accordance with the GDPR.
FIS has updated its Data Processing Addendum to include the new SCCs as well as ‘supplementary measures’.
Can FIS continue to transfer EU personal data to Third Countries outside the EEA including US?
In addition, FIS follows the EDPB guidelines on international transfers and takes appropriate actions to mitigate any privacy risks arising as a result of the Schrems II Judgment.
What steps FIS will take to support its clients?
(i) your regular FIS contact such as relationship manager (if you have one);
(ii) FIS product/service provided to you; and
(iii) FIS contracting entity.
FIS will be updating its client contracts to incorporate the new SCCs, where applicable, in accordance with the required deadlines. If you are an existing client and the new SCCs apply to you, FIS will be in touch shortly with the required new DPA.
What steps FIS will take with its partners and vendors located outside of the EEA?
What is FIS’ approach to the GDPR and Schrems II?
FIS understands and agrees with the principles of the GDPR and all relevant data privacy laws that people have the right to understand how their personal data is handled and they should have control over their data. FIS will continue monitoring regulatory guidance and take necessary actions as a result of the Schrems II Judgement and the new SCCs.