LARGE UNION LTD.

(LUL) Part 4
– EU SME CO. EXAMPLE
DATA TRANSFERS –
PROCESSOR AGREEMENT
Safeguards should be in place for transfers in US & Canada
LUL contract with EasyStore
Article 28 – guarantees and specific processing activities
Cloud Provider commitment
What happens to data stored with it upon termination of services should be clearly
spelled out in the agreement, including secure deletion of data, in both countries
where the data is stored.
ADEQUACY/PRIVACY SHIELD
Understand the requirements of the Privacy Shield for the U.S. transfers and the adequacy
decision for the Canada transfers
U.S. Department of Commerce’s list of companies under the Privacy Shield.
David should also review EasyStore’s privacy policy required as part of the Privacy Shield
program
David would look at the EC’s adequacy decision for Canada
Determine any potential impacts on the rights and freedoms of the EU data subjects.
Create a Report that establishes a baseline level of compliance !!!