Comments submitted to the European Data Protection Board on EDPB Recommendations 01/2020 on Measures that Supplement Transfer Tools to Ensure Compliance with the EU Level of Protection of Personal Data, Comments submitted to the European Data Protection Board on EDPB Recommendations 01/2020 on Measures that Supplement Transfer Tools to Ensure Compliance with the EU Level of Protection of Personal Data, , Comments to EDPB Recommendations by Swire and Mayo 2020