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Author: Hogan Lovells International LLP

Breaking: EU-U.S. Privacy Shield to Replace Safe Harbor

The European Commission has announced an agreement today with the United States Department of Commerce (DOC) to replace the invalidated Safe Harbor agreement on transatlantic data flows with a new EU-U.S. “Privacy Shield.” The Privacy Shield aims to address the requirements set out by the European Court of Justice in its Oct. 6, 2015 ruling by imposing stronger obligations on companies, providing stronger monitoring and enforcement by the DOC and Federal Trade Commission (FTC), and making commitments regarding access to information on the part of public authorities. In announcing the agreement, Vice-President Ansip noted his belief that the Privacy Shield...

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Safe Harbor aftermath – Never a reason to panic

It’s close to 7pm on a Friday evening and my team are trying their best to manage our clients’ stress and frantic desperation. Jokes about how much they love Max Schrems are shared by email. In the meantime, we are diligently working our way through endless charts of dataflows and attempting to cover every single one of them with intra-group agreements, model clauses and the like. It’s been like this since October and the pace is anything but slowing down. Sorting out international data transfers has always been a difficult compliance challenge for multinationals but the current levels of...

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