Subject: RE: Model Contract Question
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Wed, 11 Apr 2001 04:50:00 -0700 (PDT)

Each Data Protection Supervisory Authority can be contacted; some may
review. We are not aware of one supervisory authority that can bind all
authorities in all states with its approval of a contract. But if you are
not required by law to pre-submit your contract, I question whether you want
to do so.  You may get multiple interpretations. We believe that you should
develop your best judgment about whether your documents conform to the legal
requirements and submit the contract where you are required to do so, not
seek advice from the regulatory authorities about the specifics of your
contracts.  After all, as we indicated this area of the law is still in
flux, and we would hate to see you lock into a position with an
authority--unless you absolutely had to do so.