With reference to Attensi's Data Processing Agreement:
Attensi, as a processor, is granted a general authorisation to engage subcontractors ("Sub-processors") in the processing of the Personal Data, subject to the procedure for engaging Sub-processors as set out in the aforementioned agreement. The list of approved sub-processors is found in the table below:
NOTE: The EU Court of Justice passed a judgement in the so-called Schrems II-case this summer, which entails that the EU-US Privacy Shield is invalid as legal basis for transfer of personal data from the EU/EEA to the US. In addition, the EU judgement sets out new requirements for transfers of personal data outside the EU/EEA.
Attensi has assessed the implications of the judgement for our operations, and implemented measures to ensure compliance with the new requirements. The measures involve that Attensi has stopped transfer of personal data to sub-contractors in the US, has changed its sub-contractors in the US to subcontractors in EU/EEA. Excepted from the transfers is processing of SCORM courses hosted in the Attensi PORTAL. This transfer is in progress.
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