International Transfers Expert Subgroup
6 February 2019, 10.00 am
The coordinator of the expert subgroup presented the items subject to discussion that could not be
addressed at the expert subgroup meeting of 29 January 2019. Moreover, an additional point on BCRs
submitted for an opinion by the EDPB was agreed to be discussed during the conference call.
Article 46 guidelines
The document will be resent to gather comments from the members of the expert subgroup. The
deadlines will be communicated by the coordinator. The expert subgroup will discuss it at the next
meeting on March.
The coordinator of the expert subgroup will ask the Chair whether on the composition of the drafting
BCRs and SCCs questions
The members of the expert subgroup discussed questions asked by some SAs.
There were two more questions that were not discussed, because the SAs who sent them did not
attend the conference call. These questions will be discussed in the next meeting of the expert
subgroup in March.
Procedure for approval of ad hoc SCCs
The members of the expert subgroup were asked to send comments and suggestions regarding this
topic by 25 February 2019. The outcome will be discussed during the next meeting of the expert
subgroup on March. The members of the expert subgroup agreed on asking the Plenary for a mandate
to work on this.
Update of common views guide
NL will endeavour to prepare a first draft for the next meeting, but will first check internally.
SAs that expressed interest to host the next training will check internally and give an update during
the next ITS meeting.
BCRs draft decisions submitted to EDPB for an opinion
The discussion evolved around the BCRs submitted to IMI by one SA and how to proceed. For one of
them the members of the expert subgroup did not provide comments, but for the other one there
were some comments.
- Members of the expert subgroup will send their comments and suggestions regarding the Guidelines
on Art. 46 and cooperation procedure for ad hoc clauses by 25 February 2019.
- Coordinator of the expert subgroup will ask the Plenary for a mandate to work on the cooperation
mechanism for the adoption of ad-hoc clauses.
- Coordinator of the expert subgroup will ask the Chair on the composition of the drafting team of the
guidelines on Article 46.
Annex: Attendance List
- BE SA, CZ SA, DK SA, DE (Hessen) SA, DE SA (Fed), FR SA, FI SA, IT SA, NL SA, LU SA, SE SA, LV SA, UK
- NO SA
- European Commission
- EDPB Secretariat