The Uruguay’s data protection authority, URCDP, has removed the US from the list of appropriate territories as part of its amendment. 

Announced on September 16, the URCDP has published Resolution No. 23/021 of June 8, 2021, which establishes important changes in the international data transfer regime in Uruguay. 

Within the framework of the powers provided by the Law, the Unit can determine the appropriate territories for the transfer of personal data without requiring prior administrative authorizations.

This resolution replaces Resolution No. 4/019, of March 12, 2019, and excludes the US from the appropriate territories, suggesting the use of other mechanisms such as contractual clauses and other elements to justify the transfer, giving a period of six months for the companies to make this justification before the Unit. 

To collaborate with those data controllers and processors, Resolution No. 41/021, of September 8, 2021, was published, which includes a guide for the drafting of contractual clauses.


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