Service providers often receive or access a customer’s personal information when performing contracted services. In the employment context, service providers may include payroll processors, Human Resource Information System (HRIS) or Applicant Tracking System (ATS) platforms, outsourced IT support, data storage, AI tool providers, or security services.

Under the EU and UK General Data Protection Regulations

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

Businesses are now prohibited from transferring employee personal data from the European Economic Area (EEA) to the U.S. under the EU-U.S. Privacy Shield program. The Court of Justice of the European Union (CJEU) declared the EU-U.S. Privacy Shield invalid in Data Protection Commissioner v. Facebook Ireland and Schrems (C-311/18) (Schrems II), effective immediately. Businesses that