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Privacy Assessments

EU Cloud Code of Conduct

Cloud service providers can now show their compliance with the GDPR, in the role as a processor, and help controllers identify those compliant cloud service providers.

Contact a Specialist Build Your Compliance Roadmap

SOC for Cyber Middle

Background and Overview of the EU Cloud Code of Conduct

The General Data Protection Regulation (GDPR), which became effective in 2018, requires adoption of technical and organizational measures for controllers and processors of personal data to demonstrate compliance with the GDPR. The GDPR outlines Codes of Conduct in Article 40 as a way for organizations to demonstrate compliance against an approved and recognized set of best practices.

On May 19th, 2021, the European Data Protection Board (EDPB) adopted the EU Cloud Code of Conduct, which was then adopted by the Belgian Data Protection Authority on May 20th. This is significant as this Code was designed specifically for cloud service providers. Adherence to the Code is voluntary; however, compliance will help controllers to identify processors that adhere to the GDPR.

Who does it apply to?

The EU Cloud Code of Conduct (Code) applies to cloud service providers (CSP) (e.g., IaaS, PaaS, or SaaS) acting in the role as a processor to certify the in-scope cloud services as compliant with the EU recognized Code of Conduct. The cloud services that are included in the scope can include all cloud service offerings or a portion of the services. Selection of the cloud services to include in the scope is up to the CSP.

SOC for Cyber Middle

What does the Code include?

The applicable GDPR requirements are included in Chapter 5 and 6 of the Code. Chapter 5 includes requirements specific to privacy, or data protection requirements applicable to processors, while Chapter 6 includes security requirements. The Code is administered by Scope Europe, also referred to as the monitoring body.

There are three levels of compliance that the CSP can choose:

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Level 1

Level 1 is a self-assessment by the CSP confirming that the requirements within the Code have been met. The monitoring body will verify that the CSP complies with the Code.

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Level 2

Level 2 provides compliance to the Code utilizing existing third party assessments, audits or certifications that cover some of the Code’s requirements. The monitoring body will verify that the third party reports partially satisfy the code. When the reports do not support compliance with all of the Code requirements, the monitoring body verifies that the CSP complies with those requirements of the Code not covered by the third party reports.

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Level 3

Level 3 demonstrates compliance with every requirement outlined within the Code from third party assessments, audits or certifications. The audit reports must be internationally recognized standards and should provide sufficient information for the monitoring body to determine that the Code requirements were met.

Contact a Specialist

Chris Lippert

Chris is a Director and Privacy Technical Lead at Schellman based out of Atlanta, GA. With more than five years of experience in information assurance, Chris has a concentration in privacy-related engagements.

Meet Chris Contact Us

  • Fixed-Fee Using an outcome-based, fixed-fee pricing model based on our extensive experience
  • Scope Creep We see less than 5% of our clients that see amendments and are often the result of a scope expansion
  • Low Overhead Low overhead means a flexible financial structure

Learn more about our pricing process

Learn more about our pricing process

How much will your audit cost?

Whether it is an ISO 27001 certification, SOC 2 examination or a FedRAMP assessment, companies are often challenged by the need to address customer requirements while ensuring a return on compliance investment.

The most important factor in scoping a potential assessment is understanding what deliverable the recipient (i.e. your customer or partner) is expecting.

Once we have scoped your environment and needs, there are several factors that contribute to Schellman’s pricing:

  • Fixed-Fee Using an outcome-based, fixed-fee pricing model based on our extensive experience
  • Scope Creep We see less than 5% of our clients that see amendments and are often the result of a scope expansion
  • Low Overhead Low overhead means a flexible financial structure

Learn more about our pricing process

Learn more about our pricing process

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“Schellman” is the brand name under which Schellman & Company, LLC and Schellman Compliance, LLC provide professional services. Schellman & Company, LLC and Schellman Compliance, LLC practice as an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations and professional standards. Schellman & Company, LLC is a licensed certified public accounting firm (Florida license number AD62941) registered with the Public Company Accounting Oversight Board (PCAOB) that provides attest services to its clients, and Schellman Compliance, LLC provides nonattest cybersecurity and compliance professional services to its clients. Schellman Compliance, LLC is not a licensed CPA firm. Schellman & Company, LLC and Schellman Compliance, LLC are independently owned and are not liable for the services provided by any other entity providing services under the Schellman brand. Our use of the terms “our firm” and “we” and “us” and terms of similar import, denote the alternative practice structure conducted by Schellman & Company, LLC and Schellman Compliance, LLC.