President Trump recently fired the three democrats on the Privacy and Civil Liberties Oversight Board (PCLOB). Since these firings bring the Board to a sub-quorum level, they have the potential to significantly disrupt transatlantic transfers of employee and other personal data from the EU to the US under the EU-US Data Privacy Framework (DPF).
The…
The Swiss Federal Council has added the U.S. to the list of countries with an adequate level of data protection. Effective September 15, 2024, U.S. organizations that certify to the Swiss–U.S. Data Privacy Framework (DPF) can commence receiving transfers of personal data from Switzerland without implementing additional safeguards.
While U.S. organizations were permitted to certify…
On February 28, 2024, President Biden issued an Executive Order (EO) seeking to protect the sensitive personal data of Americans from potential exploitation by particular countries. The EO acknowledges that access to Americans’ “bulk sensitive personal data” and United States Government-related data by countries of concern can, among other things:
…fuel the creation and refinement…
The European Commission recently issued an overall positive review in its first annual report on the E.U. – U.S. Privacy Shield (“Privacy Shield”), after evaluating the Privacy Shield in its joint review with the US last month.
The Privacy Shield took effect in August 2016 replacing the EU – US Safeharbor that was invalidated by…
As we previously reported, the EU and U.S. reached agreement last week on the EU-U.S. Privacy Shield to replace the invalidated EU-U.S. Safe Harbor Program for transatlantic data transfers. While the announcement of the Privacy Shield is a relief to the thousands of companies who relied on the Safe Harbor Program, details remain unclear.…
UPDATE: Although we previously reported that a possible Safe Harbor resolution may be imminent, Bloomberg BNA is now reporting that a European Commission official has told them there may be no deal today to replace the U.S.-EU Safe Harbor Program.
According to BNA, when European Commissioner for Justice, Consumers and Gender Equality Justice Vera…
