The European Data Protection Supervisor stated that the Protocol is insufficient for data transfers
The opinion of the European Data Protection Supervisor (EDPS) of 10 September 2026, the full text of which is available in our Judykatura database, recalls the fundamental distinction between a legal basis for international cooperation and a legal basis for data transfers. The EDPS considered the Additional Protocol to the Warsaw Convention to be an instrument containing important safeguards, but one which is not in itself sufficient to justify a transfer of personal data to a third country.
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