Comments of World Privacy Forum to EDPB re: data localization and privacy
WPF provided feedback on the European Data Protection Board’s Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data. In responding to the Recommendations, we found several areas which, if improved, would enhance the stated goals of the EDPB for facilitating free flow of data while preserving fundamental rights and freedoms of individuals, including the right to protection of personal data.
We noted our concerns about the EDPB’s Recommendations apparently requiring data localization, as well as the language that appears to curtail uses for standard contractual clauses in context. The Recommendations of mandatory data localization and the removal of a key compliance tool, will lead to less, not more privacy should the recommendations go forward.
It is our hope that the EDPB will take more broadly into consideration these issues and will revise the guidance.
Read the comments: WPF Comments to EDPB regarding proposed privacy guidance