SaaS Agreements – Data Protection: UK-US Data Bridge

On Friday the 22nd of September the UK agreed its own transfer mechanism which can be used instead of UK standard contractual clauses.

From the 12 October 2023, SaaS Suppliers and SaaS Customers can start to transfer UK personal data to entities located in the USA provided that the US entity is certified under the new “UK Extension to the EU-US Data Privacy Framework” (UK-US Data Bridge).

This now means that all transfers of UK personal data made to US companies certified under the UK-US Data Bridge by SaaS companies will be deemed to be to a third country that has adequate data protection laws.

Once a US organisation has been certified and is publicly placed on the DPF List they can receive EU personal data through the DPF.

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SaaS Agreements – Data Protection: EU-US Data Privacy Framework (DPF)

In July 2023 the EU-US Data Privacy Framework, (DPF) was finally agreed between the EU and the USA. The DPF now provides a new transfer mechanism for SaaS suppliers and SaaS customers to use when transferring EU personal data to the USA. The DPF can be used instead of EU standard contractual clauses.

This means that all transfers of EU personal data made to US companies certified under the DPF by SaaS companies will be deemed to be to a third country that has adequate data protection laws.

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