In October, the Conference of the German Data Protection Commissioners issued an update (source document in German) of their "2011 Orientierungshilfe—Cloud Computing" ("Orientation Guideline—Cloud Computing"). The changes underlying the recent update discuss the employment of subcommissioned data processors by cloud service providers. The update also discusses the processing of encrypted data, reassessments of international data transfers with emphasis on U.S. NSA surveillance, and the relevance of granting the customer access to protocol data for lawful data transfer to the U.S.
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