A lot happened since Schrems-II , among others the European Data Protection Board published a FAQ document , a guidance on essential guarantees for surveillance measures and submitted another guidance , on measures that supplement transfer tools. Transfer tools are either safeguards which ensure that data subjects enjoy adequate protection of their privacy at the place and in the organisation to where their data are transferred or derogations which enable transfer essentially without adequate protection. I used the term adequate protection and previously the view was that the protection ensured need not be identical with that in the EU. The Schrems II judgment, however, speaks about equivalent protection and this is stronger. In case the derogations (according to article 49 GDPR) are used, the EDPB is of the view that the last sentence of Article 44 GDPR (All provisions in this Chapter shall be applied in order to ensure that the level of protection of natural...