Tag Archives: Safe Harbor Framework

EU-U.S. Privacy Shield Framework Joint Annual Review 2.0

By David M. Brown on Posted in Enforcement, International Privacy Law
As we previously reported here, the Federal Trade Commission (FTC) announced several enforcement actions in late 2017, on the eve of the first annual joint EU-U.S. review of the Privacy Shield Framework. Now the second annual review of the EU-U.S. Privacy Shield Framework is underway, and the FTC has announced several new enforcement actions, which … Continue Reading

Privacy Shield Update: Ahead of First Joint Review, Europeans Remain Skeptical as FTC Announces Enforcement Actions

Photo of Melinda L. McLellanBy Melinda L. McLellan and Emily R. Fedeles on Posted in Enforcement, International Privacy Law
On September 8, 2017, the Federal Trade Commission (FTC) announced enforcement actions against three companies alleged to have falsely claimed participation in the EU-U.S. Privacy Shield Framework. The move follows several months of uncertainty surrounding the Framework’s future as EU officials and privacy advocates have questioned its efficacy and validity in the run-up to the … Continue Reading

Swiss-U.S. Privacy Shield Framework to Launch April 12

Photo of Melinda L. McLellanBy Melinda L. McLellan and Emily R. Fedeles on Posted in International Privacy Law
On January 11, 2017, the U.S. Department of Commerce, the Swiss Federal Council and the Swiss Federal Data Protection and Information Commissioner (FDPIC) issued press releases announcing that an agreement has been reached on a new cross-border data transfer mechanism, the Swiss-U.S. Privacy Shield Framework (the Swiss Privacy Shield). The Swiss Privacy Shield replaces its … Continue Reading

Privacy Shield Developments and UK Data Transfers Post-Brexit

Photo of Melinda L. McLellanBy Melinda L. McLellan and Jenna N. Felz on Posted in International Privacy Law
With the UK’s Brexit referendum dominating the news out of Europe over the past week, it may have been easy to miss a key development in the continuing Privacy Shield negotiations. On Friday, June 24, news outlets reported that U.S. regulators and the European Commission had agreed on a finalized version from the Privacy Shield, a proposed … Continue Reading

German Data Protection Authority Issues Fines for Unlawful Cross-Atlantic Data Transfers

Photo of Melinda L. McLellanBy Jenna N. Felz, Melinda L. McLellan and Alexandra Beierlein on Posted in Enforcement, International Privacy Law
The Data Protection Authority of Hamburg, Germany has made good on its promise to audit cross-Atlantic data transfers in the wake of the October 2015 Safe Harbor decision.  On June 6, the Hamburg DPA announced that it had fined three companies for unlawful transfers of personal data from the EU to the United States.  According … Continue Reading

Safe Harbor Is Dead, Long Live Standard Contractual Clauses?

Photo of Melinda L. McLellanBy Melinda L. McLellan and William W. Hellmuth on Posted in Enforcement, International Privacy Law
For the past 15 years, the EU-U.S. Safe Harbor Framework has been one of the most popular data transfer mechanisms for organizations that engage in cross-border transfers of EU personal data to the United States. In the aftermath of the recent invalidation of the Safe Harbor Framework by the Court of Justice of the European … Continue Reading

What Now? What Next? FAQs and Answers Regarding the Safe Harbor Decision

Photo of Melinda L. McLellanBy Tanya Forsheit and Melinda L. McLellan on Posted in Enforcement, International Privacy Law
As we discussed in our blog post last week, on October 6, 2015, the Court of Justice of the European Union issued a judgment that invalidated the EU-U.S. Safe Harbor Framework. For the past 15 years, thousands of companies have been using the Safe Harbor Framework to transfer personal data from the EU to the … Continue Reading

EU High Court Invalidates Safe Harbor Framework for Cross-Border Data Transfers

Photo of Melinda L. McLellanPhoto of James A. ShererBy Melinda L. McLellan and James A. Sherer on Posted in Enforcement, International Privacy Law
On October 6, 2015, the Court of Justice of the European Union (CJEU) issued a highly anticipated judgment that has the potential to impact how thousands of companies transfer data from the EU to the United States. The Court’s decision effectively invalidates the European Commission’s “adequacy” determination with respect to the U.S.-EU Safe Harbor Framework, … Continue Reading
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