These new model clauses are relevant where data controllers transfer personal data for processing outside the EEA. From 15 May, any subsequent processing operating outside the EEA, is subject to the same conditions and instructions as stipulated by the data controller. The new clauses include provision that any sub-processing requires the consent of the data controller, and that the data controller has an up to date list and copies of any sub-processing contracts. These contracts and the list must be available to the Information Commissioner on request. This development will be applicable to any FE or HE institution acting as a data controller, where personal data is transferred abroad and outside the EEA for processing. For more information, please refer to http://www.out-law.com/page-11028.