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In brief

By means of Resolution No. 198/2023, published in the official gazette on 18 October 2023, the Agency of Access to Public Information (AAIP) approved the model contractual clauses included in the Implementation Guide of Model Contractual Clauses for International Personal Data Transfers of the Ibero-American Data Protection Network (MCC and IADPN, respectively).

In focus

In the absence of an adequacy decision, Argentine law recognizes self-regulation or contractual clauses as adequate guarantees for the international transfer of personal data, provided that they offer protection guarantees comparable to Argentine regulations.

Argentina has approved standard contractual clauses through Disposition No. 60-E/2016, which the AAIP committed to update when it approved its 2022-2026 Strategic Plan.

By incorporating the MCC of the IADPN into the Argentine regulatory framework, the AAIP recognizes these MCC as a valid mechanism for the international transfer of personal data to countries without adequate legislation.

In addition, by recognizing the MCC of the IADPN as a valid mechanism, the AAIP promotes coherence with international standards and facilitates collaboration with countries in the region, such as Uruguay or Peru, that have adopted similar measures.

The incorporation of these instruments, in addition to promoting security in data transfers, contributes to regulatory harmonization and consolidates Argentina’s position in the protection of privacy.

Spanish version


Guillermo Cervio is a partner in Baker McKenzie’s Buenos Aires office. With more than 30 years of experience, he is recognized as a foremost practitioner in his field. He founded the IT/C team in Argentina and was the coordinator of the LatAm IT/C team from 2008 to 2017. He is currently a member of the Steering Committee of Baker McKenzie LatAm’s IPTC team.
Guillermo has authored books and articles on legal matters. He has won awards for his book “Derecho de las Telecomunicaciones” (National Academy of Law - Mención de honor, 1998, and Austral University - premio tesina,1997) as well as for the paper he filed in the IX National Congress on Corporate Law (Tucumán, 2004). He has been a professor at the University of Buenos Aires, Austral University, Palermo University, Catholic University and CEMA. In 2003, he was awarded the Folsom fellowship grant by the Center for American and International Law in Dallas.


Martín Roth is a partner in the M&A, Real Estate and TMT practice groups in Baker McKenzie's Buenos Aires office. Martín has more than 13 years of extensive transactional domestic and international experience, focusing on the real estate and TMT industries. Prior to joining Baker McKenzie, he worked as a trainee lawyer on the Corporate, Banking/Finance and Litigation areas with a local law firm in Argentina. From 2007 to 2012, he worked in Baker McKenzie's Buenos Aires office. From 2013 to 2016, he worked as an independent attorney at another law firm. Martín rejoined the Buenos Aires office in 2016 and was named partner in July 2019.


Valentina Biondi Grane is an Associate in Baker McKenzie, Buenos Aires office.

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