Prior to the Schrems II ruling, the old-style Standard Contractual Clauses (SCCs) were often included in IT contracts. Situations where the suspension or termination of the data transfers due to the interplay between the old SCCs and the contracted IT services rarely happened in practice, but they were included. Following the Schrems II ruling, with the increased focus on enforcement of data transfers, embedding the new SCCs into IT contracts requires far greater care and attention.
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