Abstract
Abstract Other than in case of data transfers from Europe to countries without an adequate level of data protection, there is no set of standard contractual clauses - similar to the EU Model Clauses - for data transfers within countries with an adequate level data protection. In practice, this lack of such standard agreements sometimes raises questions and it (seemingly) also leaves more room to achieve compliance than in case of data transfers to countries without an adequate level of data protection. This article discusses and analyzes these questions and this “room”, with a focus on the practical implications of the use of “boilerplate” data protection clauses, i.e. generic contractual data protection clauses that are directly incorporated into commercial agreements.
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