In October, the European Commission indicated that the United States would have until January 2016 to define a new set of guidelines for the transfer of data in and out of EU member states following the invalidation of the Safe Harbor agreement. On Nov. 6, the EU released a new memo offering U.S. organizations guidance in their privacy obligations and making it clear that they expect the majority of the work to define a new framework to come from the United States.
Previously providing a holistic framework for U.S.-based organizations to exchange data across European Union borders, the Safe Harbor agreement was struck down in October following a ruling by the European Court of Justice. Despite ongoing discussions about a replacement framework for Safe Harbor, during an address on the topic from Brussels last week, EU leaders suggested that the U.S. will need to spearhead initiatives that support those newer frameworks.
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