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Global Data Alliance Comments on New EDPB Guidance on Data Transfers

BRUSSELS – December 21, 2020 – The Global Data Alliance today filed comments to the European Data Protection Board (EDPB) on its draft guidance on supplementary measures for cross-border personal data transfers.

“Global Data Alliance members rely on the ability to transfer data responsibly around the world to create jobs and make local industries more competitive. We share a deep and long-standing commitment to protecting data across technologies and business models, and we commend the EDPB for publishing its recommendations to help companies conduct a case-by-case assessment of their data transfers after the Schrems II decision,” said Thomas Boué, Director General, Policy – EMEA at BSA.

“Cross-border data transfers power innovation and growth across the globe for companies of all sizes in every sector of the economy — from manufacturing and farming to local start-ups and service providers. We respect the difficulty of publishing recommendations with examples that account for all circumstances of transfers,” Boué said. “However, given the breadth of businesses and industries that rely on the ability to transfer data responsibly, the Global Data Alliance encourages the EDPB to better reflect the broad range of circumstances that companies must consider in assessing data transfers. We also believe it is important to clarify that a combination of technical, contractual, or organizational safeguards may be used to correspond to a data transfer’s level of risk.”

Read the Global Data Alliance’s full submission here.

About the Global Data Alliance

The Global Data Alliance (globaldataalliance.org) is a cross-industry coalition of companies that are committed to high standards of data responsibility and that rely on the ability to transfer data around the world to innovate and create jobs. The Alliance supports policies that help instill trust in the digital economy while safeguarding the ability to transfer data across borders and refraining from imposing data localization requirements that restrict trade.

Alliance members include BSA members and American Express, Amgen, AT&T, Citi, ITB360, LEGO, Mastercard, Medtronic, Panasonic, Pfizer, Roche, UDS Technology, United Airlines, Verizon, VISA, and WD-40 Company. These companies are headquartered across the globe and are active in the advanced manufacturing, aerospace, automotive, consumer goods, electronics, energy, financial services, health, supply chain, and telecommunications sectors, among others. BSA | The Software Alliance administers the Global Data Alliance.


BSA | The Software Alliance (www.bsa.org) is the leading advocate for the global software industry before governments and in the international marketplace. Its members are among the world’s most innovative companies, creating software solutions that help businesses of all sizes in every part of the economy to modernize and grow.

With headquarters in Washington, DC, and operations in more than 30 countries, BSA pioneers compliance programs that promote legal software use and advocates for public policies that foster technology innovation and drive growth in the digital economy.


Michael O’Brien

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