What Happens if the Controller Objects to Changes in Sub-processors Under a General Authorization?
ANSWER
Under OPTION 2 of Clause 7.7 of the SCCs, the processor must explicitly inform the controller in writing of any planned changes to the agreed list of sub-processors, while respecting the agreed notice period.
If the controller objects to the proposed changes, the processor may not engage the new sub-processor (or new sub-processors).
The above answer is based on an official document of the European Commission.
You can review it at: https://ec.europa.eu/info/sites/default/files/questions_answers_on_sccs_en.pdf
A translated version of this document is also available on our blog under the title: "Standard Contractual Clauses (SCCs) – Questions and Answers".
